[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 closes 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 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
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 closes 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 draft 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 closes 30 January 2026.
Contact
Penny Hextall, Individuals and Intermediaries
Phone: (03) 6221 0624
[4143] Transfer pricing issues related to inbound distribution arrangements
Title
Draft update to Practical Compliance Guideline PCG 2019/1 Transfer pricing issues related to inbound distribution arrangements
Purpose
This draft 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 draft 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
December 2025
Contact
Abdo Dirani, Public Groups
Phone: (02) 9374 8189
[4146] Positions in relation to shares or interest in shares [updated]
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
[4191] Significant global entities – ATO compliance approach for privately owned and wealthy groups [updated]
Title
Significant global entities – ATO compliance approach for privately owned and wealthy groups
Purpose
This guidance will outline our proposed 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
To be advised
Comments
The delivery approach for the draft Guideline is currently under review. The content will be delivered through an alternative public advice and guidance product. Further information regarding the revised format and the anticipated publication date will be provided once finalised.
Contact
David Kasmarik, Private Wealth
Phone: (02) 9374 8414
[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
December 2025
Contact
Dean Karlovic, Private Wealth
Phone: (03) 9285 1686