Class Ruling

CR 2006/95W

Income tax: taxation of Joint Petroleum Development Area (JPDA) employment income: foreign tax credits - employees of Farstad Shipping (Indian Pacific) Pty Ltd

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Notice of Withdrawal

Class Ruling CR 2006/95 is withdrawn with effect from today.

1. CR 2006/95 applied from 1 July 2004 to Australian resident individuals employed by Farstad Shipping (Indian Pacific) Pty Ltd who are performing services within the Joint Petroleum Development Area (JPDA) of Timor-Leste and who have their employment income governed by Article 13 of the Taxation Code, at Annexure G of the Petroleum (Timor Sea Treaty) Act 2003.

2. CR 2006/95 deals with the application of Division 18 of the Income Tax Assessment Act 1936 (ITAA 1936) and, in particular, section 160AF of the ITAA 1936 which allowed a foreign tax credit for tax paid on foreign source income. Division 18 of the ITAA 1936 has been repealed as a result of the introduction of Division 770 of the Income Tax Assessment Act 1997 (ITAA 1997), effective from 1 July 2008. Division 770 of the ITAA 1997 allows taxpayers to claim relief in the form of a 'tax offset' for foreign income tax paid on an amount.

3. As a result of the above legislative changes, CR 2006/95 is no longer current and is withdrawn.

4. CR 2006/95 is replaced by Class Ruling CR 2010/52.

Commissioner of Taxation
6 October 2010

Not previously issued as a draft

References

ATO references:
NO 1-27RNP0U