Aurizon Network is to obtain an administratively Sample Clauses

Aurizon Network is to obtain an administratively binding advice from the ATO in respect of the SUFA structure once statutory severance is obtained Aurizon Network supports this proposal with enhancements. Aurizon Network is prepared to assume an obligation to seek (but not an obligation to obtain) an ABA in respect of the tax affairs of Aurizon Network and a notional Trust under the approved SUFA template documents. Aurizon Network notes that ABAs in respect of Aurizon Network and a notional trust may not address all taxation aspects of the SUFA structure. This is because there may be taxation implications for the Relevant Infrastructure Lessor(s) under the National Tax Equivalent Regime or Federal tax regime (if applicable). If the Relevant Infrastructure Lessor(s) was subject to taxation under either regime, Aurizon Network would not be able to seek an ABA on behalf of the Relevant Infrastructure Lessor(s). Alternatively, if the Relevant Infrastructure Lessor(s) was not subject to taxation under either regime, no ABA would be applicable. On this basis, Aurizon Network considers that this proposed obligation is too broad in scope, and requests the QCA to ensure the scope is limited only to Aurizon Network and a notional trust. Aurizon Network has advised the QCA and other parties that the ATO is unlikely to provide an ABA in respect of SUFA template documents. However, Aurizon Network will seek the ABAs in respect of the template, provided the costs of seeking them are added into the operating costs otherwise approved under the access undertaking from time to time. Aurizon Network briefed the QCA on 7 April 2014 on Aurizon Network’s proposed tax ruling process (Appendix 2).
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