[4056] Decline in value of a depreciating asset
Title
Addendum to Taxation Ruling
Taxation Ruling TR 2017/1 Income tax: deductions for mining and petroleum exploration expenditure
Purpose
The addendum will clarify that, having considered the statutory context and legislative history of the relevant provision, the Commissioner maintains their view that the ordinary meaning of the term ‘exploration or prospecting’ is as previously expressed.
Expected completion
To be advised
Comments
The draft update to Taxation Ruling TR 2017/1DC Income tax: deductions for mining and petroleum exploration expenditure published on 10 December 2025. Comments period closes 6 February 2026.
Contact
Liam Cox, Office of the Chief Tax Counsel
Phone: (03) 9275 2458
[4083] Rental properties
Title
Final 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. It 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
To be advised
Comments
Draft Taxation Ruling TR 2025/D1 Income tax: rental property income and deductions for individuals who are not in business published on 12 November 2025. Comments period closed 30 January 2026.
Contact
Penny Hextall, Individuals and Intermediaries
Phone: (03) 6221 0624
Title
Final Practical Compliance Guideline
Apportionment of rental property deductions – ATO compliance approach
Purpose
This Guideline will complement the final Taxation 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
To be advised
Comments
Draft Practical Compliance Guideline PCG 2025/D6 Apportionment of rental property deductions – ATO compliance approach published on 12 November 2025. Comments period closed 30 January 2026.
Contact
Penny Hextall, Individuals and Intermediaries
Phone: (03) 6221 0624
Title
Final 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 final Taxation Ruling and explain our compliance approach regarding the integrity rule relating to holiday homes.
Expected completion
To be advised
Comments
Draft Practical Compliance Guideline PCG 2025/D7 Application of section 26-50 of the Income Tax Assessment Act 1997 to holiday homes that you also rent out – ATO compliance approach published on 12 November 2025. Comments period closed 30 January 2026.
Contact
Penny Hextall, Individuals and Intermediaries
Phone: (03) 6221 0624
[4143] Transfer pricing issues related to inbound distribution arrangements
Title
Update to Practical Compliance Guideline PCG 2019/1 Transfer pricing issues related to inbound distribution arrangements
Purpose
This update is the first of the anticipated updates noted at paragraphs 14 and 42 of the Guideline. It ensures the Guideline and profit markers for assessing transfer pricing risk remain relevant and up to date. The update also clarifies the scope of the application of the Guideline and reportable tax position schedule by introducing a 'white zone' for certain taxpayers.
Expected completion
To be advised
Comments
The draft update to Practical Compliance Guideline PCG 2019/1DC Transfer pricing issues related to inbound distribution arrangements published on 10 December 2025. Comments period closes 13 February 2026.
Contact
Abdo Dirani, Public Groups
Phone: (02) 9374 8189
[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 1A of former Part IIIAA of the Income Tax Assessment Act 1936.
Expected completion
Early 2026
Contact
Jay Gao, Public Groups
Phone: (02) 9374 5168
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 proposed compliance approach in allocating resources to consider the application of Division 1A 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
Early 2026
Contact
Jay Gao, Public Groups
Phone: (02) 9374 5168
[4205] Are you carrying on a business? [new]
Title
Draft Taxation Ruling
Are you carrying on a business?
Purpose
This draft Ruling will set out the Commissioner’s view on the indicators that are relevant when determining whether an individual is in business.
Expected completion
April 2026
Contact
Kayla Grant, Small Business
Phone: (03) 9377 1976
[4252] Long-term construction contracts
Title
Draft Practical Compliance Guideline
Recognition of income under property development agreements involving long-term construction contracts – ATO compliance approach
Purpose
This draft Guideline will set out our proposed compliance approach to long-term construction contract arrangements (projects that span a period of greater than one year) in the property and construction industry.
Expected completion
Early 2026
Contact
Dean Karlovic, Private Wealth
Phone: (03) 9285 1686