EV 1052104051752currentnon-binding advice

Deductions for dividends on-paid to non-resident owner The Commissioner has determined that, based on the arrangement in the present case, each of the conditions in paragraphs 46FA(1)(a) to (g) of the Income Tax Assessment Act 1936 (ITAA 1936)will be satisfied. As such, the resident company will be entitled to a deduction under section 46FA of the ITAA 1936.

Non-binding edited private advice. This is an edited version of private advice the ATO gave to a specific taxpayer about their own circumstances. You cannot rely on it — it is not binding and provides no protection for anyone else (see PS LA 2008/4). Use it as a guide to the ATO’s thinking, not as authority.

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