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Edited version of private advice
Authorisation Number: 1052280560590
Date of advice: 04 October 2024
Ruling
Subject: Fringe benefits tax
Question 1
The taxpayer sought a ruling regarding whether the transfer of employees currently employed by one employer to a future employer would cause the Commissioner of Taxation to determine that section 67 of the Fringe Benefits Tax Assessment Act 1986 (FBTAA) applies to increase, by any amount, the 'aggregate fringe benefits" in respect of any fringe benefits provided to those employees in the future.
Answer 1
It was determined that section 67 would not apply to this arrangement.