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2025 completed issues

This page will display a list of completed public advice and guidance issues for the 2025 year.

Last updated 30 March 2025

[4111] Supplies of land with no improvements involving multiple titles [new]

Purpose

The Addendum to Goods and Services Tax Ruling GSTR 2006/6 Goods and services tax: improvements on the land for the purposes of Subdivision 38-N and Division 75 reflects the decision of the Full Federal Court in Commissioner of Taxation v Landcom [2022] FCAFC 204 – that where a single piece of land comprising separately titled lots is supplied, each lot is considered separately when applying the unimproved land provisions.

Outcome

The Addendum to GSTR 2006/6 published on 19 March 2025.

[4162] Foreign superannuation fund and applicable fund earnings [new]

Purpose

This Decision impact statement outlines the ATO's response to this case, which concerns when a taxpayer is able to make a choice to have applicable fund earnings with respect to a payment from a foreign superannuation fund assessed to an Australian complying superannuation fund rather than themselves.

Outcome

The Decision impact statement on Came v Federal Commissioner of Taxation [2023] AATA 3951, originally published on 4 December 2024, was updated on 13 March 2025 following the closure of the comments period.

[4176] Disqualifying individuals from acting as trustee for superannuation entities

Purpose

This Decision impact statement outlines the ATO's views on the decision in this case, which set aside the Commissioner's decision to disqualify the applicant under subsection 126A of the Superannuation Industry (Supervision) Act 1993 from acting as a trustee or a responsible officer of a corporate trustee of superannuation entities.

Outcome

The Decision impact statement on Merchant and Commissioner of Taxation [2024] AATA 1102 published on 15 January 2025.

[4208] Luxury cars and trading stock

Purpose

This Decision impact statement outlines the ATO’s response to this case, which considered whether the use of luxury cars as trading stock and for public display in a museum was solely for a ‘quotable purpose’ under the A New Tax System (Luxury Car Tax) Act 1999.

Outcome

The Decision impact statement on Automotive Invest Pty Limited v Commissioner of Taxation [2024] HCA 36 published on 11 December 2024.

QC103769