[4083] Rental properties [updated]
Title
Final Taxation Ruling
Rental property income and deductions for individuals who are not in business
Purpose
This Ruling 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
May 2026
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
Serena Hicken, Individuals and Intermediaries
Phone: 08 9268 5606
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
May 2026
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
Serena Hicken, Individuals and Intermediaries
Phone: 08 9268 5606
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
May 2026
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
Serena Hicken, Individuals and Intermediaries
Phone: 08 9268 5606
[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
To be advised
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
To be advised
Contact
Jay Gao, Public Groups
Phone: 02 9374 5168
[4205] Are you carrying on a business?
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
Mid 2026
Contact
Kayla Grant, Small Business
Phone: 03 9377 1976
[4252] Long-term construction contracts
Title
Final Practical Compliance Guideline
Recognition of income under property development agreements involving long-term construction contracts – ATO compliance approach
Purpose
This 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.
This Guideline accompanies Taxpayer Alert TA 2026/1 Contrived property development arrangements between related parties that defer recognition of income and exploit tax losses.
Expected completion
To be advised
Comments
Draft Practical Compliance Guideline PCG 2026/D2 Application of Part IVA to property development arrangements involving long-term construction contracts – ATO compliance approach published on 1 April 2026. Comments period closes 15 May 2026.
Contact
Dean Karlovic, Private Wealth
Phone: 03 9285 1686