Draft Taxation Ruling

TR 2019/D1W

Income tax: income of international organisations and persons connected with them that is exempt from income tax

• Please note that the PDF version is the authorised version of this withdrawal notice.

Notice of Withdrawal

Draft Taxation Ruling TR 2019/D1 is withdrawn with effect from today.

1. TR 2019/D1, which issued on 27 March 2019, considered the income of international organisations and persons connected with them that is exempt income. The income is made exempt by section 6-20 of the Income Tax Assessment Act 1997 because of the application of the International Organisations (Privileges and Immunities) Act 1963 (IOPI Act).

2. TR 2019/D1 updated the ATO view expressed in Taxation Ruling TR 92/14 Income tax: taxation privileges and immunities of prescribed International Organisations and their staff and Taxation Determination TD 92/153 Income tax: who is a 'person who holds an office' as specified in various regulations made under the International Organisations (Privileges and Immunities) Act 1963? (both withdrawn on 29 March 2019, the date of issue of TR 2019/D1) to incorporate the decisions of the High Court in Macoun v Commissioner of Taxation [2015] HCA 44 and Commissioner of Taxation v Jayasinghe [2017] HCA 26.

3. The Commissioner's view as first outlined in TR 2019/D1, to the extent it continues to apply, has been incorporated into draft Taxation Ruling TR 2024/D2 Income tax: exempt income of international organisations and persons connected with them, which issued today. TR 2024/D2 expands the Commissioner's view in TR 2019/D1. It has been issued in draft form to allow for further community consultation and comment.

Commissioner of Taxation
22 May 2024

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References

ATO references:
NO 1-CXW6RE8