Notice of Addenda

Administered by Department of the Treasury

Legislation au C2018G00119 In force Gazette

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COMMISSIONER OF TAXATION

The Commissioner of Taxation, Chris Jordan, gives notice of the following Rulings, copies of which can be obtained from http://ato.gov.au/law.

NOTICE OF ADDENDA
Ruling Number	Subject	Brief Description
LCG 2015/1	Law Companion Guidelines: purpose, nature and role in ATO’s public advice and guidance	The Addendum amends LCG 2015/1 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/2	Section 177DA of the Income Tax Assessment Act 1936: schemes that limit a taxable presence in Australia	The Addendum amends Law Companion Guideline LCG 2015/2 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/3	Subdivision 815-E of the Income Tax Assessment Act 1997: Country-by-Country reporting	The Addendum amends Law Companion Guideline LCG 2015/3 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/4	Attribution Managed Investment Trusts: 'clearly defined rights'	The Addendum amends Law Companion Guideline LCG 2015/4 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/5	Attribution Managed Investment Trusts: choice to treat separate classes as separate AMITs	The Addendum amends Law Companion Guideline LCG 2015/5 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/6	Attribution Managed Investment Trusts: character flow through for AMITs	The Addendum amends Law Companion Guideline LCG 2015/6 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/7	Attribution Managed Investment Trusts: attribution on a 'fair and reasonable' basis	The Addendum amends Law Companion Guideline LCG 2015/7 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/8	Attribution Managed Investment Trusts: the rules for working out trust components - allocation of deductions	The Addendum amends Law Companion Guideline LCG 2015/8 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/9	Attribution Managed Investment Trusts: trustee shortfall taxation - section 276-420	The Addendum amends Law Companion Guideline LCG 2015/9 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/10	Attribution Managed Investment Trusts: administrative penalties for recklessness or intentional disregard of the tax law – section 288-115	The Addendum amends Law Companion Guideline LCG 2015/10 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/11	Attribution Managed Investment Trusts: annual cost base adjustments for units in an AMIT and associated transitional rules	The Addendum amends Law Companion Guideline LCG 2015/11 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/12	Attribution Managed Investment Trusts: dividend, interest and royalty withholding	The Addendum amends Law Companion Guideline LCG 2015/12 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/13	Attribution Managed Investment Trusts: withholding in respect of ‘fund payments’	The Addendum amends Law Companion Guideline LCG 2015/13 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/14	Managed Investment Trusts: widely-held tests - wholly-owned entity of an Australian government agency	The Addendum amends Law Companion Guideline LCG 2015/14 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2015/15	Managed Investment Trusts: the non-arm's length income rule in sections 275-605, 275-610 and 275-615 of the Income Tax Assessment Act 1997	The Addendum amends Law Companion Guideline LCG 2015/15 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/1	GST and carrying on an enterprise in the indirect tax zone (Australia)	The Addendum amends Law Companion Guideline LCG 2016/1 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/2	Small Business Restructure Roll-over: consequences of a roll-over	The Addendum amends Law Companion Guideline LCG 2016/2 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/3	Small Business Restructure Roll-over: genuine restructure of an ongoing business	The Addendum amends Law Companion Guideline LCG 2016/3 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/4	Attribution Managed Investment Trusts: ‘carry forward trust component deficit’	The Addendum amends Law Companion Guideline LCG 2016/4 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/5	Foreign resident capital gains withholding regime: the Commissioner’s variation power	The Addendum amends Law Companion Guideline LCG 2016/5 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/6	Foreign resident capital gains withholding regime: amount payable to the Commissioner	The Addendum amends Law Companion Guideline LCG 2016/6 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/7a	Foreign resident capital gains withholding regime: options	The Addendum amends Law Companion Guideline LCG 2016/7 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/8	Superannuation reform: transitional CGT relief for complying superannuation funds and pooled superannuation trusts	The Addendum amends Law Companion Guideline LCG 2016/8 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/9	Superannuation reform: transfer balance cap	The Addendum amends Law Companion Guideline LCG 2016/9 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/10	Superannuation reform: Defined benefit income streams – non-commutable, lifetime pensions and lifetime annuities	The Addendum amends Law Companion Guideline LCG 2016/10 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/11	Superannuation Reform: concessional contributions – defined benefit interests and constitutionally protected funds	The Addendum amends Law Companion Guideline LCG 2016/11 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2016/12	Superannuation Reform: Total Superannuation Balance	The Addendum amends Law Companion Guideline LCG 2016/12 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2017/1	Superannuation reform: capped defined benefit income streams – pensions or annuities paid from non-commutable, life expectancy or market linked products	The Addendum amends Law Companion Guideline LCG 2017/1 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
LCG 2017/3	Superannuation reform: Superannuation death benefits and the transfer balance cap	The Addendum amends Law Companion Guideline LCG 2017/3 to remove references to Law Companion Guideline due to change of name to Law Companion Ruling. The Addendum applies on and from 19 February 2018.
TR 2006/10	Public Rulings	The Addendum amends Taxation Ruling TR 2006/10 to provide for the name change of Law Companion Guidelines to Law Companion Rulings. The Addendum applies on and from 19 February 2018.

Overview

The Commissioner of Taxation, Chris Jordan, has issued an addendum to various Law Companion Guidelines (LCG) and a Taxation Ruling (TR) to reflect the name change from "Law Companion Guidelines" to "Law Companion Rulings." This change was implemented to provide a more accurate reflection of the legal status and authority of these documents, which offer guidance on the interpretation and application of tax law. This addendum was enacted to ensure consistency and clarity in the naming conventions used by the Australian Taxation Office (ATO). The purpose of this change is to avoid confusion and to better communicate the authoritative nature of the guidelines. The Addendum applies from 19 February 2018, and is part of the ongoing efforts by the ATO to improve the quality and reliability of public advice and guidance on tax matters.

Scope and Application

The notice of the Addendum published by the Commissioner of Taxation under the Commonwealth of Australia's legal framework pertains to various Law Companion Guidelines (LCG) and Taxation Rulings (TR), which have been amended to reflect the change of name from "Law Companion Guideline" to "Law Companion Ruling." These amendments are applicable from 19 February 2018, and encompass LCGs related to schemes that limit a taxable presence in Australia, country-by-country reporting, Attribution Managed Investment Trusts, and Managed Investment Trusts, as well as TR 2006/10, which deals with public rulings. The changes are intended to streamline the ATO's public advice and guidance by updating the nomenclature. This Addendum applies to all entities and individuals who are subject to the Income Tax Assessment Act 1936 and the Income Tax Assessment Act 1997, and it is designed to provide clarity and consistency in the ATO's guidance. There are no exclusions, exemptions, or thresholds specified in the Addendum, and it does not extend or restrict the application of the underlying Acts through subordinate instruments.

Key Provisions

The key provisions of the Gazetted notice from the Commissioner of Taxation relate to the amendment of existing Law Companion Guidelines (LCG) and Taxation Rulings (TR) due to a name change from "Law Companion Guideline" to "Law Companion Ruling" (Gazetted Notice, Commissioner of Taxation). Specifically, the Addendum amends each relevant guideline or ruling to correct the terminology and ensure consistency with the new naming convention. These amendments apply from 19 February 2018. The obligations and requirements imposed by the Act on the parties or entities it governs include the need to update their internal documentation, references, and systems to reflect the new terminology of "Law Companion Ruling" instead of "Law Companion Guideline". This is necessary to ensure compliance with the updated guidance provided by the Australian Taxation Office (ATO). The ATO expects that those subject to these guidelines and rulings will take reasonable steps to familiarise themselves with the updated documents and incorporate any necessary changes into their compliance and reporting processes. There are no direct offences, penalties, or civil/criminal consequences for breach specified within the notice itself. However, failure to comply with the updated Law Companion Rulings could potentially lead to non-compliance with the relevant provisions of the Income Tax Assessment Act 1936 and the Income Tax Assessment Act 1997. Non-compliance with these Acts can result in penalties, interest charges, and potential legal action by the ATO. The specific penalties for non-compliance with the tax laws are not outlined in the notice, but can include fines and imprisonment for serious or repeated offences. It is essential for taxpayers and their advisers to ensure they are aware of and comply with the updated Law Companion Rulings to avoid potential penalties and interest charges.

Area of Law: Taxation Law
Instrument: Gazette Notice
Concepts: Definitions & Interpretation; Reporting & Disclosure Obligations; Compliance Obligations

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Sourced from the Federal Register of Legislation at 26 August 2026. For the latest information on Australian Government law please go to https://www.legislation.gov.au.

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