Notice of Rulings and Withdrawal of Rulings 22 July 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, and under subsection 358-20(1) of Schedule 1 to the Taxation Administration Act 1953 of the withdrawal 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 2026/43 | Emmerson Resources Limited – scrip for scrip roll-over | This Ruling sets out the income tax consequences for the former shareholders of Emmerson Resources Limited in relation to the disposal of their ordinary shares in that company to Tennant Consolidated Mining Group Pty Ltd in exchange for CHESS Depositary Interests in Pan African Resources plc, under a scheme of arrangement implemented on 1 July 2026. This Ruling applies to shareholders specified in the Ruling from 1 July 2026 to 30 June 2027. |
CR 2026/44 | Toro Energy Limited – scrip for scrip roll-over for shareholders | This Ruling sets out the income tax consequences for holders of ordinary shares in Toro Energy Limited who disposed of their shares in that comapny to Iso Australia Operations Pty Ltd in exchange for shares in IsoEnergy Ltd. on 25 June 2026. This Ruling applies to shareholders specified in the Ruling from 1 July 2025 to 30 June 2026. |
PR 2026/10 | Fringe benefits tax consequences for employers under an Origin electric vehicle subscription agreement | This Ruling sets out the fringe benefits tax consequences for an employer of an employee to whom Origin Energy Electricity Limited provides an Electric Vehicle on a subscription basis under the terms and conditions of an Electric Vehicle Subscription Agreement. This Ruling applies to employers specified in the Ruling from 1 April 2026 to on or before 31 March 2029. |
NOTICE OF ADDENDA | ||
Ruling number | Subject | Brief description |
TR 2006/11 | Private rulings | This Addendum amends Taxation Ruling TR 2006/11 to address recent developments in case law and the promoter penalty laws in Division 290 of Schedule 1 to the Taxation Administration Act 1953. This Addendum applies both before and after its date of issue. |
TD 2012/2 | Income tax: when is the shortfall interest charge incurred for the purposes of paragraph 25 5(1)(c) of the Income Tax Assessment Act 1997? | This Addendum amends Taxation Determination TD 2012/2 to reflect recent legislative amendments. This Addendum applies to the changes to the deductibility of shortfall interest charge in relation to assessments for income years starting on or after 1 July 2025. |
NOTICE OF WITHDRAWAL | ||
Ruling number | Subject | Brief description |
TD 2020/5 | Income tax: what are the reasonable travel and overtime meal allowance expense amounts for the 2020-21 income year? | This Determination is being withdrawn with effect from 23 July 2026 as its date of effect has ceased. The Determination will continue to be legally binding on the Commissioner for the relevant period to which it relates. |