Class Ruling

CR 2006/1W

Income tax: Macquarie Goodman Industrial Trust - Macquarie Goodman Group merger stapling arrangement

• Please note that the PDF version is the authorised version of this withdrawal notice.
  This document incorporates revisions made since original publication. View its history and amending notices, if applicable.

FOI status:

This Ruling provides you with the following level of protection: This publication (excluding appendices) is a public ruling for the purposes of the Taxation Administration Act 1953. A public ruling is an expression of the Commissioner's opinion about the way in which a relevant taxation 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, we must apply the law to you in the way set out in the ruling (or in a way that is more favourable for you if we are satisfied that the ruling is incorrect and disadvantages you, and we are not prevented from doing so by a time limit imposed by the law). You will be protected from having to pay any under-paid tax, penalty or interest in respect of the matters covered by this ruling if it turns out that it does not correctly state the law how the current law applies to you.

Withdrawal

1. This Ruling is withdrawn and ceases to have effect after 30 June 2005. The Ruling continues to apply, in respect of the tax provisions ruled upon, to all entities within the specified class who entered into the scheme during the term of the Ruling.

Commissioner of Taxation
18 January 2006

Not previously issued as a draft

References

ATO references:
NO 2006/813

Related Rulings/Determinations:

CR 2006/2

Subject References:
Capital distribution rights
Capital gains
CGT cost base
CGT events
CGT reduced cost base
CGT share value shifting
cost base adjustments
fixed trusts
return of capital on shares
share consolidations
stapled companies
stapled structure
stapled trusts
time of CGT event
value shifting - entity interests direct value shifting rules

Legislative References:
ITAA 1936 6(1)
ITAA 1997 Div 104
ITAA 1997 102-25
ITAA 1997 104-70
ITAA 1997 104-70(3)
ITAA 1997 104-70(4)
ITAA 1997 104-70(6)
ITAA 1997 104-155
ITAA 1997 104-155(5)(c)
ITAA 1997 109-5
ITAA 1997 109-5(1)
ITAA 1997 109-10
ITAA 1997 110-25
ITAA 1997 110-55
ITAA 1997 112-25
ITAA 1997 112-25(4)
ITAA 1997 Div 725
ITAA 1997 725-50(b)
ITAA 1997 725-55
ITAA 1997 Subdiv 727-E
ITAA 1997 727-360
Copyright Act 1968
TAA 1953