EV 1052239803068currentnon-binding advice

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).

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.

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