Notice of Rulings, Notice of Addenda

COMMISSIONER OF TAXATION

The Commissioner of Taxation, Chris Jordan, gives notice of the following Rulings, copies of which can be obtained from Branches of the Australian Taxation Office or at http://law.ato.gov.au.

NOTICE OF RULINGS
Ruling Number	Subject	Brief Description
CR 2013/20	Income tax: merger of Cromwell Property Fund and Cromwell Property Group	The Ruling outlines the tax consequences for Cromwell Property Fund unit holders. The Ruling applies from 1 July 2012 to 30 June 2013.
PR 2013/4	Income tax: W.A.. Blue Gum Project 2013	The Ruling outlines the tax consequences for W.A. Blue Gum Project 2013 members. The Product Ruling applies prospectively from 20 March 2013, the date this Product Ruling is made.

NOTICE OF ADDENDA
PR 2007/26	Income tax: deductibility of interest incurred on borrowings in relation to the Macquarie Fusion Funds – June 2007 Offer	The Addendum amends PR 2007/26 to reflect the ATO view with respect to the application of Division 247 of the Income Tax Assessment Act 1997 to interest incurred on the Interest and Put Protection Fee Loan, as set out in Taxation Determination TD 2013/1. The Addendum applies on and from 28 March 2007.
PR 2007/91	Income tax: deductibility of interest incurred on borrowings in relation to the Macquarie Fusion Funds – November 2007 Offer	The Addendum amends PR 2007/91 to incorporate amendment to Division 247 of the Income Tax Assessment Act 1997 and Division 247 of the Income Tax (Transitional Provisions) Act 1997 relating to capital protected borrowings; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest Loan, as set out in Taxation Determination TD 2013/1. The Addendum applies on and from 31 October 2007.
PR 2008/26	Income tax: deductibility of interest incurred on borrowings in relation to the Macquarie Fusion Funds – June 2008 Offer	The Addendum amends PR 2008/26 to incorporate amendment to Division 247 of the Income Tax Assessment Act 1997 and Division 247 of the Income Tax (Transitional Provisions) Act 1997 to adjust the benchmark interest rate used to determine the cost of capital protection on a capital protected borrowing from the Reserve Bank of Australia’s Indicator Lending Rate for Personal Unsecured Loans to the RBA’s Indicator Lending Rate for Standard Variable Housing Loans plus 100 basis points; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest Loan, as set out in Taxation Determination TD 2013/1. The Addendum applies on and from 19 March 2008.
PR 2008/64	Income tax: deductibility of interest incurred on borrowings in relation to Macquarie Fusion Funds – November 2008 Offer	The Addendum amends PR 2008/64 to incorporate amendments to Division 247 of the Income Tax Assessment Act 1997 to adjust the benchmark interest rate used to determine the cost of capital protection on a capital protected borrowing from the Reserve Bank of Australia’s Indicator Lending Rate for Personal Unsecured Loans to the RBA’s Indicator Lending Rate for Standard Variable Housing Loans plus 100 basis points; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest Loan, as set out in Taxation Determination TD 2013/1. The Addendum applies on and from 17 September 2008.
PR 2009/32	Income tax: deductibility of interest incurred on borrowings in relation to Macquarie Fusion Funds – June 2009 Offer	The Addendum amends PR 2009/32 to incorporate amendment to Division 247 of the Income Tax Assessment Act 1997 to adjust the benchmark interest rate used to determine the cost of capital protection on a capital protected borrowing from the Reserve Bank of Australia’s Indicator Lending Rate for Personal Unsecured Loans to the RBA’s Indicator Lending Rate for Standard Variable Housing Loans plus 100 basis points; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest and Put Protection Fee Loan, as set out in Taxation Determination TD 2013/1. The Addendum applies on and from 13 May 2009.
PR 2009/51	Income tax: deductibility of interest incurred on borrowings in relation to Macquarie Fusion Funds – November 2009 Offer	The Addendum amends PR 2009/51 to incorporate amendment to Division 247 of the Income Tax Assessment Act 1997 to adjust the benchmark interest rate used to determine the cost of capital protection on a capital protected borrowing from the Reserve Bank of Australia’s Indicator Lending Rate for Personal Unsecured Loans to the RBA’s Indicator Lending Rate for Standard Variable Housing Loans plus 100 basis points; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest and Put Protection Fee Loan, as set out in Taxation Determination TD 2013/1. The Addendum applies on and from 14 October 2009.
PR 2010/13	Income tax: deductibility of interest incurred on borrowings in relation to Macquarie Fusion Funds – June 2010 Offer	The Addendum amends PR 2010/13 to incorporate amendment to Division 247 of the Income Tax Assessment Act 1997 to adjust the benchmark interest rate used to determine the cost of capital protection on a capital protected borrowing from the Reserve Bank of Australia’s Indicator Lending Rate for Personal Unsecured Loans to the RBA’s Indicator Lending Rate for Standard Variable Housing Loans plus 100 basis points; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest and Put Protection Fee Loan, as set out in Taxation Determination TD 2013/1. The Addendum applies on and from 19 May 2010.

NOTICE OF ADDENDA

Ruling Number

Subject

Brief Description

PR 2007/26

Income tax: deductibility of interest incurred on borrowings in relation to the Macquarie Fusion Funds – June 2007 Offer

The Addendum amends PR 2007/26 to reflect the ATO view with respect to the application of Division 247 of the Income Tax Assessment Act 1997 to interest incurred on the Interest and Put Protection Fee Loan, as set out in Taxation Determination TD 2013/1.

The Addendum applies on and from 28 March 2007.

PR 2007/91

Income tax: deductibility of interest incurred on borrowings in relation to the Macquarie Fusion Funds – November 2007 Offer

The Addendum amends PR 2007/91 to incorporate amendment to Division 247 of the Income Tax Assessment Act 1997 and Division 247 of the Income Tax (Transitional Provisions) Act 1997 relating to capital protected borrowings; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest Loan, as set out in Taxation Determination TD 2013/1.

The Addendum applies on and from 31 October 2007.

PR 2008/26

Income tax: deductibility of interest incurred on borrowings in relation to the Macquarie Fusion Funds – June 2008 Offer

The Addendum amends PR 2008/26 to incorporate amendment to Division 247 of the Income Tax Assessment Act 1997 and Division 247 of the Income Tax (Transitional Provisions) Act 1997 to adjust the benchmark interest rate used to determine the cost of capital protection on a capital protected borrowing from the Reserve Bank of Australia’s Indicator Lending Rate for Personal Unsecured Loans to the RBA’s Indicator Lending Rate for Standard Variable Housing Loans plus 100 basis points; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest Loan, as set out in Taxation Determination TD 2013/1.

The Addendum applies on and from 19 March 2008.

PR 2008/64

Income tax: deductibility of interest incurred on borrowings in relation to Macquarie Fusion Funds – November 2008 Offer

The Addendum amends PR 2008/64 to incorporate amendments to Division 247 of the Income Tax Assessment Act 1997 to adjust the benchmark interest rate used to determine the cost of capital protection on a capital protected borrowing from the Reserve Bank of Australia’s Indicator Lending Rate for Personal Unsecured Loans to the RBA’s Indicator Lending Rate for Standard Variable Housing Loans plus 100 basis points; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest Loan, as set out in Taxation Determination TD 2013/1.

The Addendum applies on and from 17 September 2008.

PR 2009/32

Income tax: deductibility of interest incurred on borrowings in relation to Macquarie Fusion Funds – June 2009 Offer

The Addendum amends PR 2009/32 to incorporate amendment to Division 247 of the Income Tax Assessment Act 1997 to adjust the benchmark interest rate used to determine the cost of capital protection on a capital protected borrowing from the Reserve Bank of Australia’s Indicator Lending Rate for Personal Unsecured Loans to the RBA’s Indicator Lending Rate for Standard Variable Housing Loans plus 100 basis points; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest and Put Protection Fee Loan, as set out in Taxation Determination TD 2013/1.

The Addendum applies on and from 13 May 2009.

PR 2009/51

Income tax: deductibility of interest incurred on borrowings in relation to Macquarie Fusion Funds – November 2009 Offer

The Addendum amends PR 2009/51 to incorporate amendment to Division 247 of the Income Tax Assessment Act 1997 to adjust the benchmark interest rate used to determine the cost of capital protection on a capital protected borrowing from the Reserve Bank of Australia’s Indicator Lending Rate for Personal Unsecured Loans to the RBA’s Indicator Lending Rate for Standard Variable Housing Loans plus 100 basis points; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest and Put Protection Fee Loan, as set out in Taxation Determination TD 2013/1.

The Addendum applies on and from 14 October 2009.

PR 2010/13

Income tax: deductibility of interest incurred on borrowings in relation to Macquarie Fusion Funds – June 2010 Offer

The Addendum amends PR 2010/13 to incorporate amendment to Division 247 of the Income Tax Assessment Act 1997 to adjust the benchmark interest rate used to determine the cost of capital protection on a capital protected borrowing from the Reserve Bank of Australia’s Indicator Lending Rate for Personal Unsecured Loans to the RBA’s Indicator Lending Rate for Standard Variable Housing Loans plus 100 basis points; and to reflect the ATO view with respect to the application of Division 247 of the ITAA 1997 to interest incurred on the Interest and Put Protection Fee Loan, as set out in Taxation Determination TD 2013/1.

The Addendum applies on and from 19 May 2010.

Administered by Department of the Treasury