Class Ruling CR 2015/109
Date of effect: 1 July 2015

What this ruling is about: 1. This Ruling sets out the Commissioner's opinion on the way in which the relevant provision(s) identified below apply to the defined class of entities, who take part in the scheme to which this Ruling relates. Relevant provision(s) 2. The relevant provisions dealt with in this Ruling are: All subsequent legislative references in this Ruling are to the ITAA 1997 unless otherwise indicated. Class of entities 3. The class of entities to which this Ruling applies is either or both: who are not temporary residents (within the meaning of subsection 995-1(1)), and do not hold their relevant Pre-1 July 2009 interests, GSUs, stock options or shares as revenue assets (as defined in section 977-50) nor as trading stock (as defined in subsection 995-1(1)) - that is, they hold their relevant Pre-1 July 2009 interests, GSUs, stock options or shares on capital account. 4. The class of entities to which this Ruling applies does not extend to those subject to the Taxation of Financial Arrangements rules in Division 230 in relation to gains and losses on their Google shares and stock options. (Note: Division 230 will generally not apply to individuals, unless they have made an election for it to apply to them). Qualifications 5. The Commissioner makes this Ruling based on the precise scheme identified in this Ruling. 6. The class of entities defined in this Ruling may rely on its contents provided the scheme actually carried out is carried out in accordance with the scheme described in paragraphs 9 to 22 of this Ruling. 7. If the scheme actually carried out is materially different from the scheme that is described in this Ruling, then:

Class of entities or scheme: 3. The class of entities to which this Ruling applies is either or both: who are not temporary residents (within the meaning of subsection 995-1(1)), and do not hold their relevant Pre-1 July 2009 interests, GSUs, stock options or shares as revenue assets (as defined in section 977-50) nor as trading stock (as defined in subsection 995-1(1)) - that is, they hold their relevant Pre-1 July 2009 interests, GSUs, stock options or shares on capital account. 4. The class of entities to which this Ruling applies does not extend to those subject to the Taxation of Financial Arrangements rules in Division 230 in relation to gains and losses on their Google shares and stock options. (Note: Division 230 will generally not apply to individuals, unless they have made an election for it to apply to them). | Qualifications: 5. The Commissioner makes this Ruling based on the precise scheme identified in this Ruling. 6. The class of entities defined in this Ruling may rely on its contents provided the scheme actually carried out is carried out in accordance with the scheme described in paragraphs 9 to 22 of this Ruling. 7. If the scheme actually carried out is materially different from the scheme that is described in this Ruling, then: 8. This Ruling applies from 1 July 2015 to 30 June 2016. The Ruling continues to apply after 30 June 2016 to all entities within the specified class who entered into the specified scheme during the term of the Ruling. However, this Ruling will not apply to taxpayers to the extent that it conflicts with the terms of a settlement of a dispute agreed to before the date of issue of this Ruling (see paragraphs 75 and 76 of Taxation Ruling TR 2006/10). 9. The following description of the scheme is based on information provided by the applicant. The following documents, or relevant parts of them form part of and are to be read with the description: Note: certain information has been provided on a commercial-in-confidence basis and will not be disclosed or released under Freedom of Information legislation. 10. Google Inc. (Google) is a foreign resident company. It was listed on the NASDAQ and was the ultimate parent of the Google group. 11. Google had two classes of shares listed on the NASDAQ: | The restructure: 12. On 2 October 2015, the Google group underwent a restructure whereby Alphabet Inc. became the new parent of the Google group. The restructure involved the following steps: 13. The restructure was conducted under the General Corporation Law of the State of Delaware. 14. The restructure had no substantive effect on, nor required any investment decision by, Google shareholders. 15. The restructure did not alter the percentage ownership or rights of Google's shareholders, nor required them to pay any monetary consideration for each Alphabet share they received for the surrender of Google shares. 16. The rights attaching to shares in Alphabet are equivalent in all material respects to the rights attached to shares in Google, and the relative value of the replacement Alphabet shares is the same as the original Google shares. | Google stock plans: 17. Google maintained the Google Inc. 2004 Stock Plan and the Google Inc. 2012 Stock Plan (Plans) under which employees of the Google group were granted GSUs and stock options. Upon grant, employees became Participants in the Plans. 18. GSUs and stock options acquired by Participants were governed by the rules of the Plans, and were subject to the Google Stock Unit Agreement or the Google Stock Option Agreement, as the case required. 19. GSUs or stock options were granted to Participants for no consideration. 20. A portion of stock options held by Participants were acquired prior to 1 July 2009 (Pre-1 July 2009 interests). Google stopped granting stock options to employees in Australia from 1 July 2009. | Impact of restructure on Google stock plans: 21. Following the restructure, Alphabet assumed all the rights and obligations of Google in relation to outstanding unvested GSUs and all outstanding unvested and vested stock options under the Plans. The Plans were renamed Alphabet Inc. 2004 Stock Plan and Alphabet Inc. 2012 Stock Plan. 22. The GSUs and stock options are subject to the same terms and conditions as applied prior to the restructure, but automatically converted into GSUs and stock options over shares in Alphabet. | No ESS deferred taxing point upon restructure: 23. The restructure constituted a restructure within the meaning of both section 83A-130 and former section 139GCC of the ITAA 1936. 24. Where Participants held Pre-1 July 2009 interests, the replacement interests in Alphabet are treated as a continuation of Pre-1 July 2009 interests for the purposes of Subdivision DA of former Division 13A of the ITAA 1936, and no ESS deferred taxing point arises as a result of the restructure. 25. Where the Participants held GSUs and stock options issued on or after 1 July 2009 that have not been subject to an ESS deferred taxing point, the replacement GSUs and stock options in Alphabet are treated as a continuation of the GSUs and stock options for the purposes of section 83A-130, and no ESS deferred taxing point arises as a result of the restructure. | Disposal of GSUs, shares and stock options - CGT event A1: 26. CGT event A1 happened as a result of the disposal by a Google Shareholder of their interests in Google for replacement shares in Alphabet. Likewise, CGT event A1 happened as a result of the disposal by a Google Option Holder of their stock options which have been subject to an ESS deferred taxing point, for replacement stock options in Alphabet. 27. CGT event A1 also happened as a result of the disposal by a Participant of their Pre-1 July 2009 interests, GSUs and stock options that have not been subject to an ESS deferred taxing point, for replacement GSUs and stock options in Alphabet. 28. The time of CGT event A1 was when the disposal of the interests occurred, which was on the date of restructure (paragraph 104-10(3)(b)). 29. A Google Shareholder or a Google Option Holder made a capital gain from CGT event A1 happening if the capital proceeds from the disposal of a Google share or stock option exceeded its cost base. A Google Shareholder or a Google Option Holder made a capital loss if the capital proceeds from the disposal of a Google share or stock option were less than its reduced cost base (subsection 104-10(4)). 30. Likewise, a Participant made a capital gain from CGT event A1 happening if the capital proceeds from the disposal of a Pre-1 July 2009 interest, GSU or stock option that have not been subject to an ESS deferred taxing point exceeded its cost base. A Participant made a capital loss if the capital proceeds from the disposal of a Pre-1 July 2009 interest, GSU or stock option were less than its reduced cost base (subsection 104-10(4)). 31. However, any capital gain or loss arising from the disposal of a Pre-1 July 2009 interest, GSU or stock option that have not been subject to an ESS deferred taxing point is disregarded pursuant to subsection 130-80(1). | Application of Division 615 roll-over: 32. A Google Shareholder is eligible to choose roll-over under Division 615. 33. Roll-over relief under Division 615 is not available for any capital gain or capital loss made on the disposal of stock options. 34. A Google Shareholder who chooses roll-over under Division 615 will disregard any capital gain or capital loss made from the disposal of Google shares for Alphabet shares at the time of the restructure. 35. For Google Shareholders who choose roll-over relief under Division 615, the first element of the cost base and reduced cost base of each Alphabet share they have acquired under the restructure will be the total of the cost bases of all Google shares (worked out when the Google Shareholder disposed of their shares) apportioned over the number of Alphabet shares (sections 124-15 and 615-40). 36. For the purposes of determining whether a capital gain made from any later disposal of Alphabet shares is eligible to be treated as a discount capital gain, a Google shareholder who chooses roll-over relief under Division 615 will be taken to have acquired their Alphabet shares on the same date they acquired their Google shares (item 2 of the table in subsection 115-30(1)). | Application of scrip for scrip roll-over under Subdivision 124-M: 37. A Google Shareholder cannot obtain a scrip for scrip roll-over under Subdivision 124-M as they are eligible to choose roll-over under Division 615 (subsection 124-795(3)). 38. A Google Option Holder who made a capital gain from the disposal of their stock options is eligible to choose scrip for scrip roll-over under Subdivision 124-M. Scrip for scrip roll-over is not available for a capital loss. 39. A Google Option Holder who chooses for the scrip for scrip roll-over to apply will disregard any capital gain made on the disposal. 40. For Google Option Holders who choose for the scrip for scrip roll-over to apply, the first element of the cost base and reduced cost base of each replacement stock option in Alphabet received is determined by reasonably attributing to it the cost base of each stock option exchanged (subsection 124-785(2)). 41. For the purposes of determining whether a capital gain made from any later disposal of Alphabet stock options is eligible to be treated as a discount capital gain, a Google Option Holder who chooses scrip for scrip roll-over under Subdivision 124-M will be taken to have acquired their stock options in Alphabet on the same date they acquired their Google stock options (item 2 of the table in subsection 115-30(1)). Commissioner of Taxation 16 December 2015 | Pre-1 July 2009 interests: 42. By reason of subsection 83A-5(2) of the IT(TP)A 1997, Subdivision 83A-C (and the rest of Division 83A to the extent that it relates to the Subdivision) applies in relation to the Pre-1 July 2009 interests because: 43. The ESS deferred taxing point for rights is usually worked out under section 83A-120. However, because Subdivision 83A-C applies to the Pre-1 July 2009 interests by virtue of subsection 83A-5(2) of the IT(TP)A 1997, subsection 83A-5(4) of the IT(TP)A 1997 applies. 44. Paragraph 83A-5(4)(b) of the IT(TP)A 1997 provides that the ESS deferred taxing point for Pre-1 July 2009 interests is the cessation time mentioned in former subsection 139B(3) of the ITAA 1936, subject to subsection 83A-120(3). 45. Therefore, whether an ESS deferred taxing point arises as a consequence of the restructure will depend on whether a cessation time mentioned in former subsection 139B(3) of the ITAA 1936 results from the restructure. 46. Former Subdivision DA of the ITAA 1936 can affect whether a Participant is treated as having disposed of a right or ceased employment. Provided that the conditions under former section 139DR of the ITAA 1936 are met, former subsection 139DQ(1) of the ITAA 1936 provides that the replacement rights that the Participants acquired as a result of the restructure are considered a continuation of the Pre-1 July 2009 interests. 47. The restructure as described in the scheme description is a restructure for the purposes of subsection 139DQ(1) of the ITAA 1936, having satisfied former 139GCC of the ITAA 1936. 48. Participants who held Pre-1 July 2009 interests meet the conditions under former section 139DR of the ITAA 1936 as: 49. Accordingly, the replacement options in Alphabet are considered a continuation of the Pre-1 July 2009 interests, and therefore the restructure did not trigger an ESS deferred taxing point. | GSUs and stock options acquired after 1 July 2009 that have not been subject to an ESS deferred taxing point: 50. Where the Participant's replacement GSUs or stock options are, for the purposes of section 83A-130, treated as a continuation of GSUs or stock options in Google, the restructure alone would not trigger an ESS deferred taxing point. 51. Section 83A-130 relevantly provides that where as a result of a change in ownership (including the structure of the ownership) of a company (the old company): the replacement ESS interests will, for the purposes of Division 83A, be treated as a continuation of the employee's ESS interests in the old company. 52. The restructure as described in the scheme description is a restructure for the purposes of section 83A-130, having satisfied subparagraph 83A-130(1)(a)(ii) and a Participant: 53. Accordingly, the Participant's replacement ESS interests are, for the purposes of Division 83A, treated as a continuation of the ESS interests in Google, and the restructure does not cause an ESS deferred taxing point to occur. | CGT treatment of Pre-1 July 2009 interests, GSUs, stock options that have not been subject to an ESS deferred taxing point: 54. CGT event A1 happened upon the disposal of Pre-1 July 2009 interests, GSUs and stock options in Google in exchange for GSUs and stock options in Alphabet at the time of the restructure. 55. Pursuant to subsection 104-10(4), a capital gain will arise upon the conversion of ESS interests in Google to ESS interests in Alphabet if the capital proceeds from the disposal were more than the ESS interest's cost base. Similarly, a capital loss will arise if the capital proceeds from the disposal were less than the ESS interest's cost base. 56. However, subsection 130-80(1) applies to disregard any capital gain or capital loss made from CGT event A1 happening to the Pre-1 July 2009 interests, GSUs and stock options, as: | Conditions for roll-over under Division 615 are satisfied: 57. The roll-over relief provided under Division 615 enables a member of a company to disregard a capital gain or capital loss from a share or a unit that is either disposed of, or redeemed or cancelled, as part of a reorganisation of the affairs of the company, where the member becomes the owner of new shares in another company in exchange. 58. Division 615 contains a number of conditions for eligibility to choose roll-over. The main conditions that are relevant to the disposal of shares in Google are: 59. Under the restructure, Google Shareholders received ordinary shares in Alphabet for their shares in Google. Following the restructure, Alphabet owns all the shares in Google, and Google Shareholders own all of the shares in Alphabet, in a percentage equal to the percentage of shares they previously held in Google. All shareholders own a whole number of shares in Alphabet. 60. Accordingly, Google Shareholders satisfy the conditions for roll-over under Division 615. 61. For Google Shareholders who choose roll-over relief under Division 615, the roll-over consequences are set out in paragraphs 34 to 36 of this Ruling. | Conditions for scrip for scrip roll-over are satisfied: 62. Scrip for scrip roll-over enables a shareholder or an option holder to disregard a capital gain made from a share or option to acquire shares that is disposed of as part of a corporate takeover or scheme of arrangement if the shareholder or option holder receives a replacement share or option in the exchange. It also provides special rules for calculating the cost base and reduced cost base of the replacement share or option. 63. Scrip for scrip roll-over is unavailable where a shareholder or an option holder is eligible to choose roll-over under Division 615 or Division 122. 64. Subdivision 124-M contains a number of conditions for, and exceptions to, a shareholder or option holder being eligible to choose scrip for scrip roll-over. The main conditions that are relevant to this scheme are: 65. Under the scheme, the conditions for a Google Option Holder to be eligible to choose scrip for scrip roll-over under Subdivision 124-M are satisfied. 66. For Google Option Holders who choose scrip for scrip roll-over to apply, the roll-over consequences are set out in paragraphs 39 to 41 of this Ruling. 67. The following is a detailed contents list for this Ruling: © AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products). Not previously issued as a draft

Ruling: No ESS deferred taxing point upon restructure: 23. The restructure constituted a restructure within the meaning of both section 83A-130 and former section 139GCC of the ITAA 1936. 24. Where Participants held Pre-1 July 2009 interests, the replacement interests in Alphabet are treated as a continuation of Pre-1 July 2009 interests for the purposes of Subdivision DA of former Division 13A of the ITAA 1936, and no ESS deferred taxing point arises as a result of the restructure. 25. Where the Participants held GSUs and stock options issued on or after 1 July 2009 that have not been subject to an ESS deferred taxing point, the replacement GSUs and stock options in Alphabet are treated as a continuation of the GSUs and stock options for the purposes of section 83A-130, and no ESS deferred taxing point arises as a result of the restructure. | Disposal of GSUs, shares and stock options - CGT event A1: 26. CGT event A1 happened as a result of the disposal by a Google Shareholder of their interests in Google for replacement shares in Alphabet. Likewise, CGT event A1 happened as a result of the disposal by a Google Option Holder of their stock options which have been subject to an ESS deferred taxing point, for replacement stock options in Alphabet. 27. CGT event A1 also happened as a result of the disposal by a Participant of their Pre-1 July 2009 interests, GSUs and stock options that have not been subject to an ESS deferred taxing point, for replacement GSUs and stock options in Alphabet. 28. The time of CGT event A1 was when the disposal of the interests occurred, which was on the date of restructure (paragraph 104-10(3)(b)). 29. A Google Shareholder or a Google Option Holder made a capital gain from CGT event A1 happening if the capital proceeds from the disposal of a Google share or stock option exceeded its cost base. A Google Shareholder or a Google Option Holder made a capital loss if the capital proceeds from the disposal of a Google share or stock option were less than its reduced cost base (subsection 104-10(4)). 30. Likewise, a Participant made a capital gain from CGT event A1 happening if the capital proceeds from the disposal of a Pre-1 July 2009 interest, GSU or stock option that have not been subject to an ESS deferred taxing point exceeded its cost base. A Participant made a capital loss if the capital proceeds from the disposal of a Pre-1 July 2009 interest, GSU or stock option were less than its reduced cost base (subsection 104-10(4)). 31. However, any capital gain or loss arising from the disposal of a Pre-1 July 2009 interest, GSU or stock option that have not been subject to an ESS deferred taxing point is disregarded pursuant to subsection 130-80(1). | Application of Division 615 roll-over: 32. A Google Shareholder is eligible to choose roll-over under Division 615. 33. Roll-over relief under Division 615 is not available for any capital gain or capital loss made on the disposal of stock options. 34. A Google Shareholder who chooses roll-over under Division 615 will disregard any capital gain or capital loss made from the disposal of Google shares for Alphabet shares at the time of the restructure. 35. For Google Shareholders who choose roll-over relief under Division 615, the first element of the cost base and reduced cost base of each Alphabet share they have acquired under the restructure will be the total of the cost bases of all Google shares (worked out when the Google Shareholder disposed of their shares) apportioned over the number of Alphabet shares (sections 124-15 and 615-40). 36. For the purposes of determining whether a capital gain made from any later disposal of Alphabet shares is eligible to be treated as a discount capital gain, a Google shareholder who chooses roll-over relief under Division 615 will be taken to have acquired their Alphabet shares on the same date they acquired their Google shares (item 2 of the table in subsection 115-30(1)). | Application of scrip for scrip roll-over under Subdivision 124-M: 37. A Google Shareholder cannot obtain a scrip for scrip roll-over under Subdivision 124-M as they are eligible to choose roll-over under Division 615 (subsection 124-795(3)). 38. A Google Option Holder who made a capital gain from the disposal of their stock options is eligible to choose scrip for scrip roll-over under Subdivision 124-M. Scrip for scrip roll-over is not available for a capital loss. 39. A Google Option Holder who chooses for the scrip for scrip roll-over to apply will disregard any capital gain made on the disposal. 40. For Google Option Holders who choose for the scrip for scrip roll-over to apply, the first element of the cost base and reduced cost base of each replacement stock option in Alphabet received is determined by reasonably attributing to it the cost base of each stock option exchanged (subsection 124-785(2)). 41. For the purposes of determining whether a capital gain made from any later disposal of Alphabet stock options is eligible to be treated as a discount capital gain, a Google Option Holder who chooses scrip for scrip roll-over under Subdivision 124-M will be taken to have acquired their stock options in Alphabet on the same date they acquired their Google stock options (item 2 of the table in subsection 115-30(1)). Commissioner of Taxation 16 December 2015


Appendix: Pre-1 July 2009 interests: 42. By reason of subsection 83A-5(2) of the IT(TP)A 1997, Subdivision 83A-C (and the rest of Division 83A to the extent that it relates to the Subdivision) applies in relation to the Pre-1 July 2009 interests because: 43. The ESS deferred taxing point for rights is usually worked out under section 83A-120. However, because Subdivision 83A-C applies to the Pre-1 July 2009 interests by virtue of subsection 83A-5(2) of the IT(TP)A 1997, subsection 83A-5(4) of the IT(TP)A 1997 applies. 44. Paragraph 83A-5(4)(b) of the IT(TP)A 1997 provides that the ESS deferred taxing point for Pre-1 July 2009 interests is the cessation time mentioned in former subsection 139B(3) of the ITAA 1936, subject to subsection 83A-120(3). 45. Therefore, whether an ESS deferred taxing point arises as a consequence of the restructure will depend on whether a cessation time mentioned in former subsection 139B(3) of the ITAA 1936 results from the restructure. 46. Former Subdivision DA of the ITAA 1936 can affect whether a Participant is treated as having disposed of a right or ceased employment. Provided that the conditions under former section 139DR of the ITAA 1936 are met, former subsection 139DQ(1) of the ITAA 1936 provides that the replacement rights that the Participants acquired as a result of the restructure are considered a continuation of the Pre-1 July 2009 interests. 47. The restructure as described in the scheme description is a restructure for the purposes of subsection 139DQ(1) of the ITAA 1936, having satisfied former 139GCC of the ITAA 1936. 48. Participants who held Pre-1 July 2009 interests meet the conditions under former section 139DR of the ITAA 1936 as: 49. Accordingly, the replacement options in Alphabet are considered a continuation of the Pre-1 July 2009 interests, and therefore the restructure did not trigger an ESS deferred taxing point. | GSUs and stock options acquired after 1 July 2009 that have not been subject to an ESS deferred taxing point: 50. Where the Participant's replacement GSUs or stock options are, for the purposes of section 83A-130, treated as a continuation of GSUs or stock options in Google, the restructure alone would not trigger an ESS deferred taxing point. 51. Section 83A-130 relevantly provides that where as a result of a change in ownership (including the structure of the ownership) of a company (the old company): the replacement ESS interests will, for the purposes of Division 83A, be treated as a continuation of the employee's ESS interests in the old company. 52. The restructure as described in the scheme description is a restructure for the purposes of section 83A-130, having satisfied subparagraph 83A-130(1)(a)(ii) and a Participant: 53. Accordingly, the Participant's replacement ESS interests are, for the purposes of Division 83A, treated as a continuation of the ESS interests in Google, and the restructure does not cause an ESS deferred taxing point to occur. | CGT treatment of Pre-1 July 2009 interests, GSUs, stock options that have not been subject to an ESS deferred taxing point: 54. CGT event A1 happened upon the disposal of Pre-1 July 2009 interests, GSUs and stock options in Google in exchange for GSUs and stock options in Alphabet at the time of the restructure. 55. Pursuant to subsection 104-10(4), a capital gain will arise upon the conversion of ESS interests in Google to ESS interests in Alphabet if the capital proceeds from the disposal were more than the ESS interest's cost base. Similarly, a capital loss will arise if the capital proceeds from the disposal were less than the ESS interest's cost base. 56. However, subsection 130-80(1) applies to disregard any capital gain or capital loss made from CGT event A1 happening to the Pre-1 July 2009 interests, GSUs and stock options, as: | Conditions for roll-over under Division 615 are satisfied: 57. The roll-over relief provided under Division 615 enables a member of a company to disregard a capital gain or capital loss from a share or a unit that is either disposed of, or redeemed or cancelled, as part of a reorganisation of the affairs of the company, where the member becomes the owner of new shares in another company in exchange. 58. Division 615 contains a number of conditions for eligibility to choose roll-over. The main conditions that are relevant to the disposal of shares in Google are: 59. Under the restructure, Google Shareholders received ordinary shares in Alphabet for their shares in Google. Following the restructure, Alphabet owns all the shares in Google, and Google Shareholders own all of the shares in Alphabet, in a percentage equal to the percentage of shares they previously held in Google. All shareholders own a whole number of shares in Alphabet. 60. Accordingly, Google Shareholders satisfy the conditions for roll-over under Division 615. 61. For Google Shareholders who choose roll-over relief under Division 615, the roll-over consequences are set out in paragraphs 34 to 36 of this Ruling. | Conditions for scrip for scrip roll-over are satisfied: 62. Scrip for scrip roll-over enables a shareholder or an option holder to disregard a capital gain made from a share or option to acquire shares that is disposed of as part of a corporate takeover or scheme of arrangement if the shareholder or option holder receives a replacement share or option in the exchange. It also provides special rules for calculating the cost base and reduced cost base of the replacement share or option. 63. Scrip for scrip roll-over is unavailable where a shareholder or an option holder is eligible to choose roll-over under Division 615 or Division 122. 64. Subdivision 124-M contains a number of conditions for, and exceptions to, a shareholder or option holder being eligible to choose scrip for scrip roll-over. The main conditions that are relevant to this scheme are: 65. Under the scheme, the conditions for a Google Option Holder to be eligible to choose scrip for scrip roll-over under Subdivision 124-M are satisfied. 66. For Google Option Holders who choose scrip for scrip roll-over to apply, the roll-over consequences are set out in paragraphs 39 to 41 of this Ruling.


What this Ruling is about | NOT LEGALLY BINDING SECTION: | A public ruling is an expression of the Commissioner's opinion about the way in which a relevant provision applies, or would apply, to entities generally or to a class of entities in relation to a particular scheme or a class of schemes. | If you rely on this ruling, the Commissioner must apply the law to you in the way set out in the ruling (unless the Commissioner is satisfied that the ruling is incorrect and disadvantages you, in which case the law may be applied to you in a way that is more favourable for you - provided the Commissioner is not prevented from doing so by a time limit imposed by the law). You will be protected from having to pay any underpaid tax, penalty or interest in respect of the matters covered by this ruling if it turns out that it does not correctly state how the relevant provision applies to you. | Appendix 2 - Detailed contents list


Related rulings: TR 2006/10
Legislative references: ITAA 1936 ITAA 1936 Div 13A ITAA 1936 139B(3) ITAA 1936 139CB ITAA 1936 139CD ITAA 1936 Subdiv DA ITAA 1936 139DQ ITAA 1936 139DQ(1) ITAA 1936 139DR ITAA 1936 139E ITAA 1936 139GCC ITAA 1997 ITAA 1997 Div 83A ITAA 1997 Subdiv 83A-C ITAA 1997 83A-120(3) ITAA 1997 83A-130 ITAA 1997 83A-130(1)(a)(ii) ITAA 1997 104-10 ITAA 1997 104-10(3)(b) ITAA 1997 104-10(4) ITAA 1997 115-30 ITAA 1997 115-30(1) ITAA 1997 124-15 ITAA 1997 Div 122 ITAA 1997 Subdiv 124-M ITAA 1997 124-785(2) ITAA 1997 124-795(3) ITAA 1997 130-80 ITAA 1997 130-80(1) ITAA 1997 130-80(1)(a) ITAA 1997 130-80(1)(b) ITAA 1997 130-80(1)(d)(ii) ITAA 1997 130-80(2)(a) ITAA 1997 130-80(2)(b) ITAA 1997 Div 230 ITAA 1997 Div 615 ITAA 1997 615-5(1)(b) ITAA 1997 615-5(1)(c) ITAA 1997 615-15 ITAA 1997 615-20(1)(a) ITAA 1997 615-20(1)(b) ITAA 1997 615-20(2) ITAA 1997 615-25(1) ITAA 1997 615-25(3) ITAA 1997 615-40 ITAA 1997 977-50 ITAA 1997 995-1(1) IT(TP)A 1997 83A-5 IT(TP)A 1997 83A-5(2) IT(TP)A 1997 83A-5(4) IT(TP)A 1997 83A-5(4)(b) TAA 1953