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Advice under development – capital gains tax issues

We are developing advice and guidance on the following capital gains tax issue.

Last updated 5 December 2024

[3953] Back-to-back CGT rollovers

Title

Draft Taxation Determination

Planned sequential transactions and the 'nothing else' condition of a rollover

Purpose

This guidance will provide the Commissioner’s view on the use of rollovers for certain arrangements which may include the interpretation and application of the ‘nothing else’ condition in CGT rollovers.

Expected completion

Early 2025

Comments

The ATO is currently looking at arrangements where rollovers are used, including arrangements where rollovers are used in conjunction with another rollover or other transactions, and the public advice and guidance that would be appropriate to provide clarity to the ATO's position on these arrangements. This includes rollovers that have a ‘nothing else’ requirement.

Contact

Tara McLachlan, Private Wealth

Phone: (07) 3149 5339

Tara.McLachlan@ato.gov.au

[4172] Application of CGT event K6

Title

Draft Taxation Ruling

Draft update to Taxation Ruling TR 2004/18 Income tax: capital gains: application of CGT event K6 (about pre-CGT shares and pre-CGT trust interests) in section 104-230 of the Income Tax Assessment Act 1997

Purpose

The draft update will revise aspects of TR 2004/18 about how the capital gain is calculated when a CGT event K6 happens. The update will focus on the interpretation and application of subsection 104-230(6) of the Income Tax Assessment Act 1997, including the approach to working out which items of post-CGT property relevant capital proceeds are reasonably attributable to.

Expected completion

December 2024

Contact

Heran Kim, Private Wealth

Phone: (02) 9685 8516

Heran.Kim@ato.gov.au

[4188] Deceased estates: 'double death' [updated]

Title

Draft Taxation Determination

CGT consequences under Division 128 of the Income Tax Assessment Act 1997 when a beneficiary of a deceased estate dies before a CGT asset of the deceased estate passes to them

Purpose

This guidance will clarify the Commissioner’s view on the application of the CGT rollover concession in Division 128 of the Income Tax Assessment Act 1997 when a beneficiary of a deceased estate dies before a CGT asset of the deceased estate passes to them.

Expected completion

Mid-2025

Contact

Danijela Jablanovic

Phone: (07) 3213 5864

Danijela.jablanovic@ato.gov.au

[4189] Deceased estates: right to occupy[updated]

Title

Draft Taxation Determination

What constitutes a right to occupy a dwelling 'under a deceased’s will' for the purpose of obtaining the CGT exemption in section 118-195 of the Income Tax Assessment Act 1997?

Purpose

This guidance will provide the Commissioner’s view on when an individual has a right to occupy a dwelling under a deceased’s will for the purposes of subsection 118-195(1) of the Income Tax Assessment Act 1997 to obtain a CGT main residence exemption.

Expected completion

Early 2026

Contact

Penny Hextall

Phone: (03) 8601 9423

Penny.Hextall@ato.gov.au

QC50316