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Edited version of private advice
Authorisation Number: 1052112899724
Date of advice: 5 June 2023
Ruling
Subject: Personal security provided during COVID-19
To protect the privacy and commercial in-confidence components of this private binding ruling, the following summary is provided.
The taxpayer sought a ruling in regard to whether personal security provided during Covid-19 would be a fringe benefit for the purpose of subsection 136(1) of the Fringe Benefits Tax Assessment Act 1986 (FBTAA)?
Question 1
Is the provision of security at the sites as outlined in the ruling application a fringe benefit for the purpose of section 136(1) of the Fringe Benefits Tax Assessment Act 1986 (FBTAA)?
Answer
Yes.
Question 2
If the provision of security at the sites is a fringe benefit, can the taxable value be reduced due to the operation of the 'otherwise deductible' rule under section 52 of the FBTAA?
Answer
No.