Draft Taxation Ruling TR 94/D36

TR 94/D36W - Notice of Withdrawal

Income tax: captive insurance companies - deductibility of premiums and the appropriate basis of assessment

• Please note that the PDF version is the authorised version of this withdrawal notice.

FOI status:

May be released

Notice of Withdrawal

Draft Taxation Ruling TR 94/D36 is withdrawn with effect from today.

The Ruling has been withdrawn because its reasoning is contrary to the decision in WD & HO Wills (Australia ) Pty Ltd v. FC of T 96 ATC 4223; 22ATR 168. The Commissioner though reserves the right to test judicially any captive insurance company case which exhibits blatant or objectionable features.

Commissioner of Taxation
19 January 2000

References

ATO references:
NO NAT 99/15852-2

Related Rulings/Determinations:

TR 94/D36