Notice of Rulings, Notice of Withdrawals

Administered by Department of the Treasury

Legislation au C2014G00147 In force Gazette

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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 2014/10	Income tax: share consolidation and in specie distribution: Macquarie Group Limited	The Ruling sets out the Commissioner’s opinion for holders of ordinary shares in Macquarie Group Limited. The Ruling applies from 1 July 2013 to 30 June 2014.
CR 2014/11	Income tax: demerger of Orora Limited by Amcor Limited	The Ruling sets out the Commissioner’s opinion for shareholders of Amcor Limited. The Ruling applies from 1 July 2013 to 30 June 2014.
CR 2014/12	Income tax: demerger of Recall Holdings Limited by Brambles Limited	The Ruling sets out the Commissioner’s opinion for holders of ordinary shares in Brambles Limited. The Ruling applies from 1 July 2013 to 30 June 2014.
CR 2014/13	Income tax: format of mobile phone invoice as evidence for donations to World Wide Fund for Nature via SMS.	The Ruling sets out the Commissioner’s opinion for mobile phone subscribers who: are residents of Australia within the meaning of subsection 6(1) of the Income Tax Assessment Act 1936; make a tax deductible gift to the World Wide Fund for Nature (WWF) by way of SMS to a designated mobile phone number operated by a Mobile Phone Carrier (MPC); receive a mobile phone invoice with the relevant details of the donation from the MPC; and use the mobile phone invoice as evidence to claim the donation as an allowable deduction under Division 30 of the Income Tax Assessment Act 1997. The Ruling applies from 1 February 2014 until 30 June 2019.
CR 2014/14	Income tax: Macquarie Group Employee Retained Equity Plan: share consolidation and in specie distribution: Macquarie Group Limited	The Ruling sets out the Commissioner’s opinion for employees (including directors) of Macquarie Group Limited or its subsidiaries. The Ruling applies from 1 July 2013 to 30 June 2014.

NOTICE OF WITHDRAWALS
Ruling Number	Subject	Brief Description
SCD 97/1	Superannuation contributions: what is the surcharge threshold for the 1997‑98 financial year under the Superannuation Contributions Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 97/2	Superannuation contributions: what are the indexable amounts for the 1997‑98 financial year under the Termination Payments Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 97/3	Superannuation contributions: what is the surcharge threshold for the 1997‑98 financial year under the Termination Payments Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 97/4	Superannuation contributions: what are the surchargeable contributions threshold and the indexable amounts for the 1997‑98 financial year under the Superannuation Contributions Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 98/3	Superannuation contributions: what is the surcharge threshold for the 1998‑99 financial year under the Superannuation Contributions Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 98/4	Superannuation contributions: what are the indexable amounts for the 1998‑99 financial year under the Termination Payments Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 98/5	Superannuation contributions: what is the surcharge threshold for the 1998‑99 financial year under the Termination Payments Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 98/6	Superannuation contributions: what are the surchargeable contributions threshold and the indexable amounts for the 1998‑99 financial year under the Superannuation Contributions Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 99/1	Superannuation contributions: what is the surcharge threshold for the 1999‑2000 financial year under the Superannuation Contributions Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 99/2	Superannuation contributions: what are the indexable amounts for the 1999-2000 financial year under the Termination Payments Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 99/3	Superannuation contributions: what is the surcharge threshold for the 1999‑2000 financial year under the Termination Payments Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 99/4	Superannuation contributions: what are the surchargeable contributions threshold and the indexable amounts for the 1999‑2000 financial year under the Superannuation Contributions Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 2000/1	Superannuation contributions: what is the surcharge threshold for the 2000‑2001 financial year under the Superannuation Contributions Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 2000/2	Superannuation contributions: what are the indexable amounts for the 2000‑2001 financial year under the Termination Payments Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 2000/3	Superannuation contributions: what is the surcharge threshold for the 2000‑2001 financial year under the Termination Payments Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 2000/4	Superannuation contributions: what are the surchargeable contributions threshold and the indexable amounts for the 2000‑2001 financial year under the Superannuation Contributions Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 2001/1	Superannuation contributions: what is the surcharge threshold for the 2001‑2002 financial year under the Superannuation Contributions Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 2001/2	Superannuation contributions: what are the indexable amounts for the 2001‑2002 financial year under the Termination Payments Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 2001/3	Superannuation contributions: what is the surcharge threshold for the 2001‑2002 financial year under the Termination Payments Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 2001/4	Superannuation contributions: what are the surchargeable contributions threshold and the indexable amounts for the 2001‑2002 financial year under the Superannuation Contributions Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 2002/1	Superannuation contributions: what is the surcharge threshold for the 2002‑2003 financial year under the Superannuation Contributions Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 2002/2	Superannuation contributions: what are the indexable amounts for the 2002‑2003 financial year under the Termination Payments Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 2002/3	Superannuation contributions: what is the surcharge threshold for the 2002‑2003 financial year under the Termination Payments Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 2002/4	Superannuation contributions: what are the surchargeable contributions threshold and the indexable amounts for the 2002‑2003 financial year under the Superannuation Contributions Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 2003/1	Superannuation contributions: what is the surcharge threshold for the 2003‑2004 financial year under the Superannuation Contributions Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 2003/2	Superannuation contributions: what are the indexable amounts for the 2003‑2004 financial year under the Termination Payments Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 2003/3	Superannuation contributions: what is the surcharge threshold for the 2003‑2004 financial year under the Termination Payments Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 2003/4	Superannuation contributions: what are the surchargeable contributions threshold and the indexable amounts for the 2003‑2004 financial year under the Superannuation Contributions Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 2004/1	Superannuation contributions: what is the surcharge threshold for the 2004‑2005 financial year under the Superannuation Contributions Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 2004/2	Superannuation contributions: what are the indexable amounts for the 2004‑2005 financial year under the Termination Payments Tax Imposition Act 1997?	Withdrawn without replacement.
SCD 2004/3	Superannuation contributions: what is the surcharge threshold for the 2004‑2005 financial year under the Termination Payments Tax (Assessment and Collection) Act 1997?	Withdrawn without replacement.
SCD 2004/4	Superannuation contributions: what are the surchargeable contributions threshold and the indexable amounts for the 2004‑2005 financial year under the Superannuation Contributions Tax Imposition Act 1997?	Withdrawn without replacement.

Overview

The Commissioner of Taxation, Chris Jordan, has published several rulings to provide guidance on various income tax matters. These rulings include clarifications on share consolidations, demergers, and tax-deductible donations via SMS. The rulings apply to specific financial years and are intended to address the tax consequences for shareholders and employees involved in these transactions. Notably, CR 2014/13 provides guidance for residents making donations to the World Wide Fund for Nature through SMS, using their mobile phone invoices as evidence for tax deductions. The rulings were introduced to ensure taxpayers can comply with the law and to provide certainty in these complex areas. The rulings are not exhaustive and do not replace the need for professional advice in individual circumstances.

Scope and Application

The Commissioner of Taxation has issued several rulings providing clarification on specific income tax matters, each applying to particular taxpayers and transactions during certain periods. CR 2014/10 to CR 2014/14 pertain to shareholders and employees of Macquarie Group Limited, Amcor Limited, and Brambles Limited, dealing with share consolidations, in specie distributions, and employee equity plans, respectively, for the financial years 2013-2014. CR 2014/13 is broader in scope, addressing Australian residents who make tax-deductible donations to the World Wide Fund for Nature via SMS, using their mobile phone invoices as evidence for claiming deductions from 1 February 2014 to 30 June 2019. These rulings do not specify exclusions or exemptions but are applicable nationally as they pertain to federal income tax laws. Additionally, several superannuation contribution rulings from previous years have been withdrawn without replacement, indicating that these rulings are no longer applicable or have been superseded by other legislation or rulings.

Key Provisions

The Commissioner of Taxation has issued several rulings under section 170B of the Taxation Administration Act 1953. These rulings provide guidance to taxpayers on various income tax matters. CR 2014/10 (paragraphs 1-2) provides the Commissioner's opinion for holders of ordinary shares in Macquarie Group Limited in relation to share consolidation and in specie distribution. CR 2014/11 (paragraphs 1-2) provides the Commissioner's opinion for shareholders of Amcor Limited in relation to the demerger of Orora Limited by Amcor Limited. CR 2014/12 (paragraphs 1-2) provides the Commissioner's opinion for holders of ordinary shares in Brambles Limited in relation to the demerger of Recall Holdings Limited by Brambles Limited. CR 2014/13 (paragraphs 1-4) provides the Commissioner's opinion for mobile phone subscribers who make a tax deductible gift to the World Wide Fund for Nature by way of SMS and use a mobile phone invoice as evidence to claim the donation as an allowable deduction. CR 2014/14 (paragraphs 1-2) provides the Commissioner's opinion for employees (including directors) of Macquarie Group Limited or its subsidiaries in relation to the Macquarie Group Employee Retained Equity Plan, share consolidation, and in specie distribution. The rulings impose obligations and requirements on the parties or entities they govern. For example, CR 2014/10 requires holders of ordinary shares in Macquarie Group Limited to follow the Commissioner's opinion on share consolidation and in specie distribution. CR 2014/13 requires mobile phone subscribers who make a tax deductible gift to the World Wide Fund for Nature by way of SMS to receive a mobile phone invoice with the relevant details of the donation from the Mobile Phone Carrier and use the mobile phone invoice as evidence to claim the donation as an allowable deduction. The rulings do not impose any specific obligations or requirements on the Commissioner of Taxation. The Commissioner of Taxation has withdrawn several rulings without replacement. These rulings included SCD 97/1 to SCD 2004/4, which provided information on superannuation contributions surcharge thresholds and indexable amounts for financial years 1997-98 to 2004-05. The withdrawal of these rulings means that taxpayers must seek guidance from other sources, such as the relevant legislation or other official publications, to determine the surcharge thresholds and indexable amounts for those financial years. There are no specific offences, penalties, or civil/criminal consequences mentioned for breach of the rulings. However, taxpayers who do not comply with the rulings may still be subject to general tax laws and penalties for non-compliance, such as fines or imprisonment for tax evasion or fraud. The maximum penalties for tax evasion or fraud depend on the circumstances of the offence and can range from fines to imprisonment for up to five years.

Area of Law: Taxation Law
Instrument: Gazette Notice
Concepts: Definitions & Interpretation; Offence Provisions; Compliance Obligations

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Sourced from the Federal Register of Legislation at 26 August 2026. For the latest information on Australian Government law please go to https://www.legislation.gov.au.

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