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Fixed trust The Commissioner exercised the discretion in • subsection 272-5(3) of Schedule 2F to the Income Tax Assessment Act 1936 (ITAA 1936), and • subsection 272-30(3) of Schedule 2F to the ITAA 1936. in relation to an ownership structure under which Company A owned 100% of the units in a unit trust with tax losses, and Company A was wholly owned (through interposed entities) by Company X (which is listed on an approved stock exchange).

Income Tax Assessment Act 1936 section 272-5 of Schedule 2F Income Tax Assessment Act 1936 section 272-30 of Schedule 2F

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