Taxation Ruling

TR 94/31W

Income tax: foreign tax credit: taxation of Australian resident members of Lloyd's of London

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FOI status:

Notice of Withdrawal

Taxation Ruling TR 94/31 is withdrawn with effect from today.

1. TR 94/31 is complementary to the earlier Lloyd's Rulings, that is: IT 2610; IT 2638; TR 93/5; and 93/41. It deals with some issues not covered in the earlier Rulings and makes some consequential amendments. It deals with date of death Income Tax returns and changes effected within the United Kingdom Inland Revenue subsequent to the 1991 Lloyd's year of account.

2. TR 94/31 makes reference to and relies upon earlier Lloyd's Rulings (that is, IT 2610; IT 2638; TR 93/5; and 93/41) which were all withdrawn on 28 February 2003. It contains information which is now out of date. As the Ruling cannot operate independently of the withdrawn Rulings it should also be withdrawn.

3. TR 2005/18 issued on 2 November 2005 and provides guidance to Australian resident individuals who are 'underwriting members' of Lloyd's (Names) in respect of the 'foreign loss quarantining' rules and the foreign tax credit system.

Commissioner of Taxation
2 November 2005

References

ATO references:
NO 2003/11684