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  • ATO rulings and determinations

    Autumn list of ATO rulings and determinations

    File ID

    File Title

    CR 2018/30

    Income tax: IFM Infrastructure Funds – Restructure

    CR 2018/31

    Income tax: capital gains consequences – sale of Westfield Group stapled securities to Unibail-Rodamco SE

    CR 2018/32

    Income tax: Mantra Group Limited - Employee Share Scheme - Tax Exempt Share Plan Shares disposed of under Scheme of Arrangement

    CR 2018/33

    Income tax: Life Healthcare Group Limited – Scheme of Arrangement and payment of Interim Dividend and Special Dividend

    CR 2018/34

    Income tax: Return of share capital: IPE Limited

    CR 2018/35

    Income tax: CSL Limited Non-Executive Director Rights Plan

    CR 2018/36

    Income tax: St George channel scheme – receipt of membership interests in Mallawa Irrigation Limited

    CR 2018/37

    Fringe benefits tax: employers using the EROAD System for car log book and odometer records

    CR 2018/38

    Income tax: Metcash Limited – Off-market share buy-back

    CR 2018/39

    Income tax: Fermentum Pty Ltd – transfer of shares to custodian

    CR 2018/40

    Income tax: demerger of GlyTherix Ltd by Minomic International Limited

    CR 2018/41

    Income tax: Deductibility of employer contributions to the Australian Construction Industry Redundancy Trust

    CR 2018/42

    Income tax: Theodore channel scheme – receipt of shares in Theodore Water Pty Ltd

    CR 2018/43

    Income tax: Sydney Water Corporation Networks Business Unit Retirement Scheme 2018/2019

    CR 2018/44

    Income tax: APN Outdoor Group Limited – Scheme of Arrangement and payment of Special Dividend

    CR 2018/45

    Income tax: scrip for scrip roll-over: exchange of CHESS Depositary Interests in fourteen BlackRock iShares Funds for units in fourteen new BlackRock Trusts

    CR 2018/46

    Income tax: Macquarie University Academic Staff Early Retirement Scheme 2018-2019

    CR 2018/47

    Fringe benefits tax: employer clients of Smartgroup Corporation Ltd’s wholly-owned subsidiaries who use the Smartgroup Logbook Solution for car logbook records and odometer records

    CR 2018/48

    Income tax: tax treatment of payments to members of the Australian Construction Industry Redundancy Trust

    CR 2018/49

    Income tax: scrip for scrip roll-over: acquisition of units in SGH Professional Investor Micro Cap Trust by SGH Emerging Companies Fund

    CR 2018/50

    Income tax: Insurance Australia Group Limited - Distribution and Share Consolidation

    CR 2018/51

    Income tax: Folkestone Limited – Scheme of Arrangement and Special Dividend

    CR 2018/52

    Income tax: assessable income: Australian Federal Police deployed to Jordan

    CR 2018/53

    Fringe benefits tax: employer clients of Police Financial Services Limited, trading as BankVic, who are subject to the provisions of section 57A or 65J of the Fringe Benefits Tax Assessment Act 1986 that make use of the BankVic Everyday Expenses Card

    CR 2018/54

    Income tax: demerger of Cowan Lithium Limited by Tawana Resources NL

    CR 2018/55

    Charles Darwin University Academic Staff Voluntary Early Retirement Scheme 2018

    CR 2018/56

    Charles Darwin University Professional Staff Voluntary Early Retirement Scheme 2018

    CR 2018/57

    Income tax: Rio Tinto Limited – off-market share buy-back

    CR 2018/58

    Income tax: Device Technologies Australia Pty Ltd adjustment to employee options

    CR 2018/59

    Income tax: Wesfarmers Limited – demerger of Coles Group Limited

    CR 2018/60

    Income tax: Wesfarmers Limited – demerger of Coles Group Limited – employee share schemes

    GSTD 2018/D1

    Goods and services tax: Determining the creditable purpose of acquisitions in a credit card issuing business

    GSTR 2018/1

    Goods and Services Tax: supplies of real property connected with the indirect tax zone (Australia)

    GSTR 2018/2

    Goods and services tax: supplies of goods connected with the indirect tax zone (Australia)

    LCR 2016/12DC

    Superannuation reform: total superannuation balance

    LCR 2018/5

    First Home Super Saver Scheme

    LCR 2018/6

    Diverted profits tax

    LCR 2018/7

    Residential premises deductions: travel expenditure relating to rental investment properties

    LCR 2018/8

    Expansion of the taxable payments reporting system to courier and cleaning services

    LCR 2018/9

    Housing affordability measures: contributing the proceeds of downsizing to superannuation

    LCR 2018/D6

    Expansion of the taxable payments reporting system to contractors in the courier and cleaning industries

    LCR 2018/D7

    Base rate entities and base rate entity passive income

    LCR 2018/D8

    Expansion of the taxable payments reporting system to road freight, security, investigation or surveillance, and information technology services

    LCR 2018/D9

    OECD Hybrid Mismatch Rules – Concept of Structured Arrangement

    LCR 2018/D10

    Income tax: Non-arm’s length income - expenditure incurred under a non-arm’s length arrangement

    PR 2018/7

    Income tax: tax consequences of investing in PTrackERS

    PR 2018/8

    Income tax: tax consequences for a Solar Gardener in an Enova Solar Garden Project

    PR 2018/9

    Income tax and goods and services tax: tax consequences for an Owner entering into a Concurrent Lease with Future Rent

    PR 2018/10

    Income tax and goods and services tax: tax consequences for a Participant in an urBau joint venture project

    PR 2018/11

    Income tax: OnePath Life – OneCare Policy – Life Cover, Total and Permanent Disability Cover and/or Trauma Cover – Value Protector Option

    PR 2018/12

    Income tax: Challenger CarePlus Annuity and Insurance

    PR 2018/13

    Income tax: tax consequences for Australian Policyholders of an Executive Investment Bond

    PR 2018/14

    Income tax: taxation consequences of investing in the Macquarie Tailored Portfolio Collar Facility

    PR 2018/15

    Income tax: taxation consequences for a Customer entering into a Prepay and Grow Agreement with Ruralco

    TD 2018/D4

    Income tax: thin capitalisation – valuation of debt capital for the purposes of Division 820

    TD 2018/D5

    Income tax: What type of costs are debt deductions within scope of subparagraph 820-40(1)(a)(iii) of the Income Tax Assessment Act 1997?

    TD 2018/D6

    Income tax: Can the debt and equity rules in Division 974 of the Income Tax Assessment Act 1997 limit the operation of the transfer pricing rules in Subdivision 815-B of the Income Tax Assessment Act 1997?

    TR 2005/5DC

    Income tax: ascertaining the right to tax United States (US) and United Kingdom (UK) resident financial institutions under the US and the UK Taxation Conventions in respect of interest income arising in Australia

    TR 2018/6

    Income tax: Trust vesting –consequences of a trust vesting

    TR 2018/7

    Employee remuneration trusts

      Last modified: 10 Oct 2019QC 27160