ATO Interpretative Decision

ATO ID 2002/198

Income Tax

Ordinary bundled endowment policies issued by a friendly society
FOI status: may be released

CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision.

This ATOID provides you with the following level of protection:

If you reasonably apply this decision in good faith to your own circumstances (which are not materially different from those described in the decision), and the decision is later found to be incorrect you will not be liable to pay any penalty or interest. However, you will be required to pay any underpaid tax (or repay any over-claimed credit, grant or benefit), provided the time limits under the law allow it. If you do intend to apply this decision to your own circumstances, you will need to ensure that the relevant provisions referred to in the decision have not been amended or repealed. You may wish to obtain further advice from the Tax Office or from a professional adviser.

Issue

Does a friendly society issue any life insurance policies which provide for participating benefits as defined in subsection 995-1(1) of the Income Tax Assessment Act 1997 (ITAA 1997)?

Decision

No, a friendly society does not issue any life insurance policies which provide for participating benefits as defined in subsection 995-1(1) of the ITAA 1997.

Facts

A friendly society issues ordinary bundled endowment policies.

Reasons for Decision

A friendly society issues a life insurance policy which provides a participating benefit if the definition of a participating benefit in subsection 995-1(1) of the ITAA is satisfied..

Subsection 995-1(1) of the ITAA 1997 defines participating benefit as having the same meaning as that given by section 15 of the Life Insurance Act 1995 (the Life Insurance Act).

Policies issued by friendly societies are not participating policies. Regulation 2.01A of the Life Insurance Regulations 1995 (the Regulations) modifies the application of the Life Insurance Act to friendly societies. Item 1 of Schedule 5 of the Regulations omits section 15 of the Life Insurance Act for the purposes of applying that Act to friendly societies. Therefore, policies issued by friendly societies do not provide participating benefits as defined in subsection 995-1(1) of the ITAA 1997.

Date of decision:  27 August 2001

Year of income:  Year ended 30 June 2001 and subsequent income years

Legislative References:
Income Tax Assessment Act 1997
   Subsection 995-1(1)

Life Insurance Act 1995
   Section 15

Life Insurance Regulations 1995
   Regulation 2.01A

Related ATO Interpretative Decisions
ATO ID 2002/197
ATO ID 2002/199
ATO ID 2002/200
ATO ID 2002/201

Keywords
Life assurance
Endowment insurance

Siebel/TDMS Reference Number:  DW291373

Business Line:  Public Groups and International

Date of publication:  28 February 2002

ISSN: 1445-2782