Notice of Rulings 29 April 2026
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 2026/17 | Atrum Coal Limited – return of capital | This Ruling sets out the income tax consequences for Atrum Coal Limited shareholders who were paid the return of capital on 23 December 2025. This Ruling applies to shareholders specified in the Ruling from 1 July 2025 to 30 June 2026. |
CR 2026/18 | Seven West Media Limited – acquisition by Southern Cross Media Group Limited – employee share scheme | This Ruling sets out the income tax consequences for employees of Seven West Media Limited and its subsidiaries who had shares in that company which they acquired under an employee share scheme, cancelled and replaced with restricted shares in Southern Cross Media Group Limited on 7 January 2026 by way of a scheme of arrangement. This Ruling applies to shareholders specified in the Ruling from 1 July 2025 to 30 June 2026. |
Overview
The Taxation Administration Act 1953 was enacted to provide the framework for the administration of taxation laws in Australia. One of the key roles of the Commissioner of Taxation is to issue public rulings to clarify the application of tax laws to specific situations. This helps to ensure that taxpayers are aware of their obligations and can comply with the law. The notice issued by the Commissioner of Taxation on 29 April 2026 under subsection 358-5(4) of Schedule 1 to the Taxation Administration Act 1953 provides details of two public rulings: CR 2026/17 regarding the income tax consequences for Atrum Coal Limited shareholders who received a return of capital on 23 December 2025, and CR 2026/18 regarding the income tax consequences for employees of Seven West Media Limited and its subsidiaries who acquired shares in Southern Cross Media Group Limited under an employee share scheme on 7 January 2026. These rulings aim to provide clarity and certainty to affected taxpayers and are available for review on the Australian Taxation Office website.
Scope and Application
The Notifiable Instrument F2026N00279, issued under the authority of the Taxation Administration Act 1953, concerns two specific public rulings concerning the income tax implications for particular shareholders in specific companies during a defined period. The first ruling, CR 2026/17, addresses the tax implications for shareholders of Atrum Coal Limited who received a return of capital on 23 December 2025, while the second ruling, CR 2026/18, pertains to employees of Seven West Media Limited and its subsidiaries who had shares in the company, which were subsequently cancelled and replaced with restricted shares in Southern Cross Media Group Limited on 7 January 2026. Both rulings are applicable to the specified shareholders from 1 July 2025 to 30 June 2026, providing clear guidance on the tax treatment of these transactions. The scope of these rulings is limited to the particular circumstances outlined, and the rulings do not specify any exclusions, exemptions, or thresholds beyond the specified dates and parties involved. The instrument itself does not extend or restrict application through subordinate instruments but serves to notify the public of these specific rulings.
Key Provisions
The notice of rulings issued by the Commissioner of Taxation under subsection 358-5(4) of Schedule 1 to the Taxation Administration Act 1953 pertains to two specific rulings, CR 2026/17 and CR 2026/18, which provide clarification on the income tax implications for certain shareholders and employees. CR 2026/17 addresses the tax consequences for shareholders of Atrum Coal Limited who received a return of capital on 23 December 2025, while CR 2026/18 pertains to the tax implications for employees of Seven West Media Limited and its subsidiaries who had their shares cancelled and replaced with restricted shares in Southern Cross Media Group Limited on 7 January 2026. Both rulings are applicable from 1 July 2025 to 30 June 2026.
The obligations imposed by these rulings include the requirement for the specified shareholders and employees to adhere to the income tax guidelines as outlined in the respective rulings. This involves ensuring that all tax obligations are met in accordance with the provisions set out in CR 2026/17 and CR 2026/18. For instance, shareholders of Atrum Coal Limited must report their return of capital correctly in their tax returns, while employees of Seven West Media Limited need to account for the replacement of their shares with restricted shares from Southern Cross Media Group Limited as per the ruling.
Failure to comply with the obligations stipulated in these rulings can lead to various consequences. While the notice of rulings does not explicitly state the penalties for non-compliance, under the Taxation Administration Act 1953, there could be implications such as fines or other penalties as prescribed by the relevant tax laws. The specific penalties would depend on the nature and extent of the breach, and may include both civil and criminal sanctions, as per the provisions of the Act.