Class Ruling
CR 2021/53A1 - Addendum
ICSGlobal Limited - return of share capital and special dividend
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Addendum
This Addendum is a public ruling for the purposes of the Taxation Administration Act 1953. It amends Class Ruling CR 2021/53 to clarify the assessability of the special dividend for non-residents.
CR 2021/53 is amended as follows:
Omit the paragraph; substitute:
If you are a non-resident, the special dividend is non-assessable non-exempt income and is not included in your assessable income as the special dividend was declared to be conduit foreign income (paragraph 802-15(1)(a)). You are also not liable to pay withholding tax in respect of the special dividend (paragraph 802-15(1)(b)).
Omit the paragraph.
After the paragraph text, insert table caption:
Table 1: Categories of CGT assets that are taxable Australian property
This Addendum applies from 4 August 2021.
Commissioner of Taxation
19 October 2022
© AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA
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References
ATO references:
NO 1-UZH6UFJ