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:

1. Paragraph 9

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)).

2. Paragraph 10

Omit the paragraph.

3. Paragraph 64

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

You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).

References

ATO references:
NO 1-UZH6UFJ

Business Line:  PGI