Class Ruling

CR 2006/56W

Income tax: Shell Group Restructure - Employee Share Scheme - Tax exempt

• Please note that the PDF version is the authorised version of this withdrawal notice.
  This document incorporates revisions made since original publication. View its history and amending notices, if applicable.

FOI status:

This publication provides you with the following level of protection: This publication (excluding appendixes) is a public ruling for the purposes of the Taxation Administration Act 1953. A public ruling is an expression of the Commissioner's opinion about the way in which a relevant provision applies, or would apply, to entities generally or to a class of entities in relation to a particular scheme or a class of schemes. If you rely on this ruling, we must apply the law to you in the way set out in the ruling (or in a way that is more favourable for you if we are satisfied that the ruling is incorrect and disadvantages you, and we are not prevented from doing so by a time limit imposed by the law). You will be protected from having to pay any underpaid tax, penalty or interest in respect of the matters covered by this ruling if it turns out that it does not correctly state how the relevant provision applies to you.

Withdrawal

1. This Ruling is withdrawn on and ceases to have effect after 30 June 2006. The Ruling continues to apply in respect of the relevant provisions ruled upon to all entities within the specified class who entered into the specified scheme during the term of the Ruling. Thus the Ruling continues to apply to those entities, even following its withdrawal, for the scheme entered into prior to the withdrawal of the Ruling. This is subject to there being no change in the scheme or in the entities' involvement in the scheme.

Commissioner of Taxation
14 June 2006

Not previously issued as a draft

References

ATO references:
NO 2006/9423

Related Rulings/Determinations:

CR 2006/53
CR 2006/54
CR 2006/55

Subject References:
capital gains tax
employee share scheme
exemption conditions
restructure
shares lapse or cease to exist

Legislative References:
TAA 1953
TAA 1953 Sch 1 357-75(1)
Copyright Act 1968
ITAA 1936 Pt III Div 13A
ITAA 1936 Pt III Div 13A Subdiv B
ITAA 1936 139BA
ITAA 1936 139CD
ITAA 1936 139CE
ITAA 1936 139CE(5)
ITAA 1936 139E
ITAA 1936 139FA
ITAA 1936 139FAA
ITAA 1936 139FB
ITAA 1936 139FC
ITAA 1936 139FD
ITAA 1936 139FE
ITAA 1936 139FF
ITAA 1936 139G
ITAA 1936 139GF
ITAA 1997 Pt 3-1
ITAA 1997 104-25
ITAA 1997 106-50
ITAA 1997 Pt 3-3
ITAA 1997 130-80
ITAA 1997 130-80(2)