Notice of Rulings 24 September 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 |
TR 2025/1 | Income tax: exempt income of international organisations and persons connected with them | This Ruling considers the income of international organisations and persons connected with international organisations that is exempt income. This Ruling applies both before and after its date of issue. |
TD 2025/6 | Income tax: does section 109U of the Income Tax Assessment Act 1936 only apply to arrangements where a private company gives a guarantee to another private company? | This Determination deals with the requirements for section 109U of the Income Tax Assessment Act 1936 to apply. This Determination applies both before and after its date of issue. |
CR 2025/63 | Domain Holdings Australia Limited – employee share scheme - minimum holding period | This Ruling sets out the income tax consequences for employees of Domain Holdings Australia Limited and its subsidiaries, who acquired shares in that company in a Domain Tax Exempt Share Plan and subsequently sold them on 27 August 2025 pursuant to a scheme of arrangement. This Ruling applies to employees specified in the Ruling from 1 July 2022 to 30 June 2024. |
CR 2025/64 | VGW Holdings Limited – scrip for scrip roll-over | This Ruling sets out the income tax consequences for shareholders of VGW Holdings Limited who transferred their shares to Ocean BidCo Limited on 20 August 2025. This Ruling applies to shareholders specified in the Ruling for the income year ending 30 June 2026. |
CR 2025/65 | GTN Limited – return of capital | This Ruling sets out the income tax consequences for shareholders of GTN Limited who received a return of capital payment of $0.23 per ordinary share on 11 August 2025. This Ruling applies to shareholders specified in the Ruling from 1 July 2025 to 30 June 2026. |
CR 2025/66 | Indiana Resources Limited – return of capital | This Ruling sets out the income tax consequences for shareholders of Indiana Resources Limited who received a return of capital payment of $0.05 per share on 15 August 2025. This Ruling applies to shareholders specified in the Ruling from 1 July 2025 to 30 June 2026. |
NOTICE OF ADDENDA | ||
Ruling number | Subject | Brief description |
LCR 2021/2 | Non-arm's length income – expenditure incurred under a non-arm's length arrangement | This Addendum amends Law Companion Ruling LCR 2021/2 to clarify how the amendments to section 295-550 of the Income Tax Assessment Act 1997 operate in a scheme where the parties do not deal with each other at arm's length and the trustee of a small complying superannuation fund (a complying superannuation entity with no more than 6 members including a self-managed superannuation fund), incurs non-arm's length expenditure (or where expenditure is not incurred) in gaining or producing ordinary or statutory income, and address accessibility requirements. This Addendum applies from 1 July 2018. |
TR 2010/1 | Income tax: superannuation contributions | This Addendum amends Taxation Ruling TR 2010/1 to explain the interactions between the non-arm's length income provisions and the rules concerning superannuation contributions. It also contains changes to reflect the removal of the maximum earnings test for the purpose of deducting personal contributions, which commenced from 1 July 2017. This Addendum applies both before and after date of issue, subject to the date of commencement of the legislation referred to. |