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  • ATO rulings and determinations

    Autumn list of ATO rulings and determinations

    File ID

    File Title

    CR 2019/43

    IMB Ltd - off-market share buy-back

    CR 2019/44

    Bialik College - early retirement scheme 2019

    CR 2019/45

    Spicers Limited - return of capital

    CR 2019/46

    Tomago Aluminium Company - early retirement scheme 2019

    CR 2019/47

    Victorian Department of Health and Human Services - employment termination payment

    CR 2019/48

    Hivint Pty Limited - Employee Option Plan

    CR 2019/49

    SA Lifetime Support Scheme - under the self-directed support program of services for assessed treatment and care needs

    CR 2019/50

    Helpten Pro Vehicle Telematics Solution - use for fringe benefits tax car logbook and odometer records

    CR 2019/51

    DuluxGroup Limited - Scheme of Arrangement and payment of interim and special dividends

    CR 2019/52

    Netstar Australia Pty Ltd telematics system - use for FBT car logbook record and odometer records

    CR 2019/53

    Department of Health and Human Services - SIL and STAA early retirement scheme 2019

    CR 2019/54

    Clients of EROAD (Australia) Pty Ltd who use the EROAD Fuel Tax Credits Product Report information showing litres allocated according to travel generated by EROAD Fuel Tax Credits product for fuel tax credit purposes

    CR 2019/55

    Mackay Sugar Limited - conversion of shares and variation of rights

    CR 2019/56

    Legend Corporation Limited - scheme of arrangement and special dividend

    CR 2019/57

    Ozinca Australia Pty Ltd - scrip for scrip rollover

    CR 2019/58

    DuluxGroup Limited - Employee Share Scheme - Employee Share Investment Plan shares disposed of under scheme of arrangement

    CR 2019/59

    Oceania Capital Partners Limited - off-market share buy-back

    CR 2019/60

    Avant Mutual Group Limited - retirement reward dividend

    CR 2019/61

    South Australian Councils - GST treatment of fees and charges imposed

    CR 2019/62

    Placard Pty Ltd - early retirement scheme 2019

    CR 2019/63

    Ruralco Holdings Limited - Exempt Employee Share Plan shares disposed of under scheme of arrangement

    CR 2019/64

    Ruralco Holdings Limited - Scheme of Arrangement and payment of Special Dividend

    CR 2019/65

    Fleetcare Pty Ltd telematics product - use for FBT car logbook and odometer records

    CR 2019/66

    Entwined Signage Pty Ltd in-Vehicle Monitoring System - use for car logbook and odometer records

    CR 2019/67

    QANTM Group - equity participation scheme for principals

    CR 2019/68

    Brambles Limited - return of capital

    CR 2019/69

    The University of Adelaide - early retirement scheme 2019

    CR 2019/70

    Suncorp Group Limited - return of capital

    CR 2019/71

    Villa World Limited - Scheme of Arrangement and payment of Special Dividend

    CR 2019/72

    Utilities Management Pty Ltd - early retirement scheme 2019

    CR 2019/73

    GBST Holdings Limited - Scheme of Arrangement and payment of Special Dividend

    CR 2019/74

    AIRR Holdings Limited - Scheme of Arrangement and Special Dividend

    CR 2019/75

    GARDA Capital Group Stapled Securities - scrip for scrip rollover

    CR 2019/76

    GARDA Diversified Property Fund - return of trust corpus and formation of a stapled security

    CR 2019/77

    McMillan Shakespeare Limited - off-market share buy-back

    CR 2019/78

    Quiktrak GPS tracking system - use for FBT car logbook records and odometer records

    CR 2019/79

    Goulburn-Murray Rural Water Corporation - early retirement scheme 2019

    CR 2019/80

    AXA Australia Employers - AXA SA 2019 Classic Plan share offer for Australian employees

    CR 2019/81

    AXA Australia Employers - AXA SA 2019 Leveraged Plan share offer for Australian employees

    CR 2019/82

    Fairbairn Irrigation Network Limited - receipt of shares

    CR 2019/83

    Pacific Energy Limited - Scheme of Arrangement and Special Dividend

    CR 2019/84

    Treatment of compensation payments received under the Fisheries Act 1995 (Vic) relating to the removal of commercial net fishing from the Gippsland Lakes

    FTD 2019/1

    Fuel tax: fuel tax credits - vehicles and satisfying environmental criteria

    FTD 2019/D1

    Fuel tax: fuel tax credits - vehicles and satisfying environmental criteria

    GSTR 2019/1

    Goods and services tax: supply of anything other than goods or real property connected with the indirect tax zone (Australia)

    GSTR 2019/2

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

    GSTR 2019/D2

    Goods and services tax: supply of anything other than goods or real property connected with the indirect tax zone (Australia)

    LCR 2019/2

    Consolidation: churning of joining entities

    LCR 2019/3

    OECD hybrid mismatch rules - concept of structured arrangement

    LCR 2019/4

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

    LCR 2019/5

    Base rate entities and base rate entity passive income

    LCR 2019/D3

    Non-arm's length income - expenditure incurred under a non-arm's length arrangement

    LCR 2019/D4

    The superannuation fund for foreign residents withholding tax exemption and sovereign immunity

    PR 2019/5

    Income tax: taxation consequences of investing in the Westpac Protected Equity Loan

    PR 2019/6

    Income tax: taxation consequences of investing in Bell Equity Lever Instalment Receipts

    PR 2019/7

    Income tax: PPS Mutual Professionals Choice - 2019

    TD 2019/10

    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 ?

    TD 2019/11

    Income tax: what are the reasonable travel and overtime meal allowance expense amounts for the 2019-20 income year?

    TD 2019/12

    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 2019/13

    Income tax: what is an 'employee share trust'?

    TD 2019/14

    Income tax: will a trust split arrangement of the type described in this Determination cause a new trust to be settled over some but not all assets of the original trust with the result that CGT event E1 in subsection 104-55(1) of the Income Tax Assessment Act 1997 happens?

    TD 2019/D5

    Income tax: tax incentives for early stage investors: what is an 'expense' that is 'incurred' for the early stage test?

    TD 2019/D6

    Income tax: does Subdivision 855-A (or subsection 768-915(1)) of the Income Tax Assessment Act 1997 disregard a capital gain that a foreign resident (or temporary resident) beneficiary of a resident non-fixed trust makes because of subsection 115-215(3)?

    TD 2019/D7

    Income tax: is the source concept in Division 6 of Part III of the Income Tax Assessment Act 1936 relevant in determining whether a non-resident beneficiary of a resident trust (or trustee for them) is assessed on an amount of trust capital gain arising under Subdivision 115-C of the Income Tax Assessment Act 1997 ?

    TD 2019/D8

    Income tax: what is an 'employee share trust'?

    TD 2019/D9

    Income tax: commercial debt forgiveness - does the exclusion for debts forgiven for reasons of natural love and affection require that the creditor be a natural person?

    TD 2019/D10

    Income tax: can capital gains be included under subparagraph 770-75(4)(a)(ii) of the Income Tax Assessment Act 1997 when calculating the foreign income tax offset limit?

    TD 2019/D11

    Income tax: where a liability is assumed on acquisition of a CGT asset, is the assumed liability excluded from the cost base of the asset if expenditure on discharge of the liability is deductible?

    TD 2019/D12

    Income tax: is section 951A of the US Internal Revenue Code a provision of a law of a foreign country that corresponds to section 456 or 457 of the Income Tax Assessment Act 1936 for the purpose of subsection 832-130(5) of the Income Tax Assessment Act 1997 ?

    TR 2019/4

    Income tax: capital allowances: expenditure incurred by an entity that collects, processes and provides multi-client seismic data

    TR 2019/6

    Income tax: the 'in Australia' requirement for certain deductible gift recipients and income tax exempt entities

    TR 2019/D4

    Income tax: employees: deductions for work expenses under section 8-1 of the Income Tax Assessment Act 1997

    TR 2019/D5

    Fringe benefits tax: car parking benefits

    TR 2019/D6

    Income tax: application of paragraph 8-1(2)(a) of the Income Tax Assessment Act 1997 to labour costs related to the construction or creation of capital assets

    TR 2019/D7

    Income tax: when are deductions allowed for employees' transport expenses?

      Last modified: 24 Sep 2020QC 27160