Notice of Rulings and Withdrawal of Rulings 8 October 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, and under subsection 358-20(1) of Schedule 1 to the Taxation Administration Act 1953 of the withdrawal of the following public ruling, copies of which can be obtained from ato.gov.au/law
NOTICE OF RULINGS | ||
Ruling number | Subject | Brief description |
CR 2025/70 | Wellard Limited – return of capital | This Ruling sets out the income tax consequences for shareholders of Wellard Limited who received a return of capital payment per ordinary Wellard share on 28 August 2025. This Ruling applies to shareholders specified in the Ruling from 1 July 2025 to 30 June 2026. |
CR 2025/71 | Washington H. Soul Pattinson and Company Limited – scrip for scrip roll-over | This Ruling sets out the income tax consequences for the holders of ordinary shares in Washington H. Soul Pattinson and Company Limited in relation to the acquisition of the majority of the ordinary shares in that company by Second Services Company Pty Ltd which was implemented on 23 September 2025. This Ruling applies to shareholders specified in the Ruling from 1 July 2025 to 30 June 2026. |
CR 2025/72 | Brickworks Ltd – scrip for scrip roll-over | This Ruling sets out the income tax consequences for the holders of ordinary shares in Brickworks Ltd in relation to the acquisition of those ordinary shares by Second Services Company Pty Ltd which was implemented on 23 September 2025. This Ruling applies to shareholders specified in the Ruling from 1 July 2025 to 30 June 2026. |
CR 2025/73 | Washington H. Soul Pattinson and Company Limited – combination with Brickworks Ltd – replacement of employee share scheme awards | This Ruling sets out the income tax consequences for employees of Washington H. Soul Pattinson and Company Limited (or its subsidiaries) of exchanging shares or rights in that company that they received, pursuant to the Washington H. Soul Pattinson and Company Limited’s Limited Rights Plan for shares or rights in First Services Company Ltd as part of the combination of WHSP Holdings Ltd and Brickworks Ltd on 23 September 2025. This Ruling applies to employees specified in the Ruling from 1 July 2025 to 30 June 2026. |
CR 2025/74 | Brickworks Ltd – employee share scheme – disposal of shares under a scheme of arrangement | This Ruling sets out the income tax consequences for employees of Brickworks Ltd and its wholly owned subsidiaries who participated in the Brickworks Limited Exempt Employee Share Plan to acquire ordinary shares in Brickworks Ltd which were subsequently disposed of on 23 September 2025 pursuant to a scheme of arrangement. This Ruling applies to employees specified in the Ruling from 1 July 2022 to 30 June 2026. |
NOTICE OF ERRATUM | ||
Ruling number | Subject | Brief description |
TR 2025/2 | Income tax: aspects of the third party debt test in Subdivision 820-EAB of the Income Tax Assessment Act 1997 | This Erratum corrects a minor typographical error in TR 2025/2. This Erratum applies from 1 October 2025. |
CR2025/67 | Platinum Asia Investments Limited – disposal of shares and special dividend | This Erratum corrects a minor typographical error in CR 2025/67. This Erratum applies from 1 October 2025. |
NOTICE OF WITHDRAWAL | ||
Ruling number | Subject | Brief description |
TD 93/60 | Income tax: employee share acquisition schemes: can a resident taxpayer participating in a foreign employee share acquisition scheme take advantage of a reduction in discount under subsection 26AAC(4F) of the Income Tax Assessment Act 1936? | TD 93/60 is withdrawn with effect from 9 October 2025 as it has no ongoing relevance. |