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Advice under development – income tax issues

Advice and guidance we are developing on income tax issues.

Last updated 6 October 2025

[4083] Rental properties [new]

Title

Draft Taxation Ruling

Rental property income and deductions for individuals who are not in business

Purpose

This guidance will replace Taxation Ruling IT 2167 Income Tax: rental properties – non-economic rental, holiday home, share of resident, etc. cases, family trusts cases. This guidance will also provide the Commissioner's view on the application of section 26-50 of the Income Tax Assessment Act 1997, which is an integrity rule relating to the use of holiday homes.

Expected completion

Mid 2026

Comments

Targeted consultation has been undertaken and public consultation is expected to commence in November 2025.

Contact

Ruth Geary, Individuals and Intermediaries

Phone: (02) 6058 7157

Title

Draft Practical Compliance Guideline

Apportionment of rental property deductions – ATO compliance approach

Purpose

This Guideline will complement the draft Ruling and explain our compliance approach regarding apportionment of deductions on a ‘fair and reasonable’ basis where the integrity rule relating to holiday homes does not apply.

Expected completion

Mid 2026

Comments

Targeted consultation has been undertaken and public consultation is expected to commence in November 2025.

Contact

Ruth Geary, Individuals and Intermediaries

Phone: (02) 6058 7157

Title

Draft Practical Compliance Guideline

Application of section 26-50 to rental properties which are used for holidays or recreation (‘holiday homes’)

Purpose

This Guideline will complement the draft Ruling and explain our compliance approach regarding the integrity rule relating to holiday homes.

Expected completion

Mid 2026

Comments

Targeted consultation has been undertaken and public consultation is expected to commence in November 2025.

Contact

Ruth Geary, Individuals and Intermediaries

Phone: (02) 6058 7157

[4115] Personal services business and Part IVA [updated]

Title

Final Practical Compliance Guideline

Personal services businesses and Part IVA of the Income Tax Assessment Act 1936

Purpose

This Guideline explains when we are more likely to apply resources to consider the potential application of Part IVA of the Income Tax Assessment Act 1936 (the general anti-avoidance provisions of the income tax law) to an alienation arrangement where personal services income of an individual is derived through a personal services entity that is conducting a personal services business.

Expected completion

November 2025

Comments

Draft Practical Compliance Guideline PCG 2024/D2 Personal services businesses and Part IVA of the Income Tax Assessment Act 1936 published on 28 August 2024. Comments period closed on 11 October 2024.

Contact

Sally Cummins, Small Business

Phone: (07) 3213 3299

SBPAGConsultation@ato.gov.au

[4146] Positions in relation to shares or interest in shares

Title

Draft Taxation Determination

Income tax: imputation: identification of which shares or interest in shares a ‘position’ is in relation to

Purpose

This draft Determination will set out the Commissioner’s preliminary view in identifying the relevant shareholdings when applying the integrity rules under Division 1 A of former Part IIIAA of the Income Tax Assessment Act 1936.

Expected completion

October 2025

Contact

Jay Gao, Public Groups

Phone: (02) 9374 5168

jay.gao@ato.gov.au

Title

Draft Practical Compliance Guideline

Arrangements that may reduce your economic exposure to a subset of your shares or interest in shares and impact on your franking credit tax offsets

Purpose

This draft Guideline will set out our compliance approach in allocating resources to consider the application of Division 1 A of former Part IIIAA of the Income Tax Assessment Act 1936 to arrangements where taxpayers have used financial derivative instruments to reduce the economic exposure to their Australian shares.

Expected completion

October 2025

Contact

Jay Gao, Public Groups

Phone: (02) 9374 5168

jay.gao@ato.gov.au

[4191] Significant global entities – ATO compliance approach for privately owned and wealthy groups [new]

Title

Draft Practical Compliance Guideline

Significant global entities – ATO compliance approach for privately owned and wealthy groups

Purpose

This draft Guideline will outline our compliance approach to the reporting of significant global entity status for entities that are members of privately owned and wealthy groups.

It will not apply to publicly owned or foreign-controlled groups.

Expected completion

November 2025

Contact

David Kasmarik, Private Wealth

Phone: (02) 9374 8414

David.Kasmarik@ato.gov.au

 

QC50315