Notice of Rulings 10 December 2025
The Commissioner of Taxation, Rob Heferen, gives notice by notifiable instrument under subsection 358-5(4) of Schedule 1 to the Taxation Administration Act 1953 of the following public rulings, copies of which can be obtained from ato.gov.au/law
NOTICE OF RULINGS | ||
Ruling number | Subject | Brief description |
CR 2025/85 | Wesfarmers Limited – return of capital | This Ruling sets out the income tax consequences for shareholders of Wesfarmers Limited who received the return of capital payment on 4 December 2025. This Ruling applies to shareholders specified in the Ruling from 1 July 2025 to 30 June 2026. |
CR 2025/86 | Domain Holdings Australia Limited – scheme of arrangement and special dividend | This Ruling sets out the income tax consequences of the special dividend paid by Domain Holdings Australia Limited on 19 August 2025 and the scheme of arrangement whereby Andromeda Australia SubCo Pty Limited acquired all the remaining ordinary shares in that company on 27 August 2025. This Ruling applies to shareholders specified in the Ruling from 1 July 2025 to 30 June 2026. |
PR 2025/16 | Tax consequences for a borrower being charged an ‘Indexed Loan Rate’ under a loan | This Ruling sets out the income tax consequences for specified entities in relation to a scheme involving the application of software licensed to Findexia Limited. This Ruling applies to entities specified in the Ruling from 10 December 2025 to 30 June 2028. |
PR 2025/17 | Instreet Structured Investment Pty Ltd – Instreet Masti | This Ruling sets out the income tax consequences for entities that participate as an investor in the scheme referred to as the Instreet Masti, offered by Instreet Structured Investment Pty Ltd. This Ruling applies to an entity specified in the Ruling from 10 December 2025 to 30 June 2028. |
NOTICE OF ADDENDA | ||
Ruling number | Subject | Brief description |
MT 2012/1 | Miscellaneous taxes: application of the income tax and GST laws to immediate transfer farm-out arrangements | This Addendum amends MT 2012/1 to clarify the Ruling. This Addendum applies both before and after its date of issue. |
MT 2012/2 | Miscellaneous taxes: application of the income tax and GST laws to deferred transfer farm-out arrangements | This Addendum amends MT 2012/2 to clarify the Ruling. This Addendum applies both before and after its date of issue. |
TR 2006/10 | Public rulings | This Addendum amends Taxation Ruling TR 2006/10 to update content regarding promoter penalty laws. This Addendum applies both before and after its date of issue. |