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Legal database
 

13 March 2025
 

Practice statements
PS LA 2006/15 – Update Consolidation regime - administration of
– the administrative penalty for shortfall amounts resulting from a false or misleading statement
– the shortfall interest charge, and
– the shortfall general interest charge
arising from certain adjustments required under the consolidation regime
PS LA 2011/7 – Update Settlement of debt litigation proceedings
PS LA 2020/2 – Update Administering general anti-abuse rules, such as a principal or main purposes test, included in any of Australia's tax treaties
 

12 March 2025
 

Rulings
PR 2025/2 Yolla Producers Co-operative Society Ltd - Yolla Co-Op Prepayment Program
 

Notices
TR 2006/14A2 - Addendum Income tax: capital gains tax: consequences of creating life and remainder interests in property and of later events affecting those interests
 

7 March 2025
 

Taxpayer alerts
TA 2025/1 Managed investment trusts: restructures to access the managed investment trust withholding regime
 

6 March 2025
 

Practice statements
PS LA 2003/9 - Update Online Resource Centre for Law Administration
 

5 March 2025
 

Rulings
CR 2025/20 National sporting organisations - financial support provided to elite athletes
CR 2025/21 Premier Investments Limited - distribution of shares in Myer Holdings Limited
PR 2025/1 C2 Gateway Deferred Purchase Agreement
 

Determinations
TD 2025/D2 Income tax: disregarding certain payments under section 109R of the Income Tax Assessment Act 1936 in determining how much of a loan has been repaid in situations where notional loans are involved
 

28 February 2025
 

Determinations
TD 2025/D1 Income tax: application of Part IVA of the Income Tax Assessment Act 1936 to certain early stage innovation company investment arrangements
 

Practice statements
PS LA 2025/1 Extension of time to apply for a director identification number
 

Decision impact statements
VID 770/2021 VID 526/2022 Mylan Australia Holding Pty Ltd v Commissioner of Taxation (No 2) [2024] FCA 253

interpretation NOW!
Episode 117
 

27 February 2025
 

Practice statements
PS LA 2008/2 (GA) - Update Non-treaty airlines
PS LA 2012/3 - Update Determining and applying quotas under the Excise Act 1901
 

26 February 2025
 

Legislative instrument
LI 2025/D1 Draft Taxation Laws (Requirement to Lodge a Return for the 2025 Year) Instrument 2025
LI 2025/D2 Draft Income Tax Assessment (Requirement for Parents Liable for or Entitled to Child Support to Lodge a Return for the 2025 Year) Instrument 2025
 

20 February 2025
 

Practice statements
PS LA 2013/3 (GA) - Update Treatment of input tax credits claimed by a recipient of a non-taxable supply where the Commissioner has the discretion to give a refund of the overpaid goods and services tax to the supplier due to the operation of former section 105-65 of Schedule 1 to the Taxation Administration Act 1953
PS LA 1998/1 - Update Law administration practice statements
PS LA 2006/17 - Update Self-managed superannuation funds - disqualification of individuals to prohibit them from acting as a trustee of a self-managed superannuation fund
PS LA 2011/17 - Update Debt relief, waiver and non-pursuit
 

19 February 2025
 

Rulings
CR 2025/15 Capitol Health Limited - scrip for scrip roll-over
CR 2025/16 The Trustee for Protect Severance Scheme No 2 - workers in receipt of severance payments
CR 2025/17 Leo Lithium Limited - return of capital and special dividend
CR 2025/18 Wellard Limited - return of capital
CR 2025/19 CW Group Holdings Limited - scrip for scrip roll-over
 

Notices
CR 2025/4ER2 - Erratum Boral Limited - compulsory acquisition - exchange of shares for shares in SGH Limited
 

Decision impact statements
NSD 1022 of 2022 - Full Federal Court NSD 988 of 2020 - Federal Court Mandalinic v Stone (Liquidator) [2023] FCAFC 146
 

Guidance update
Examples of tax consequences on sales of land including small-scale land subdivision
 

14 February 2025
 

Practice statements
PS LA 2004/4 (GA) – Update Taxing consumer loyalty program rewards
 

13 February 2025
 

Practice statements
PS LA 2011/22 – Update Commissioner's discretion to retain a refund
 

12 February 2025
 

Rulings
CR 2025/8 ConocoPhillips Australia Operations Pty Ltd - employee share scheme - Contributory Plan
CR 2025/9 Bravura Solutions Limited - return of capital
CR 2025/10 Anteris Technologies Ltd - scrip for scrip roll-over for option holders
CR 2025/11 Anteris Technologies Ltd - employee share scheme - treatment of options under scheme of arrangement
CR 2025/12 Anteris Technologies Ltd - scrip for scrip roll-over for shareholders
CR 2025/13 Just Eggs Pty Limited - employee share scheme - reducing the minimum holding period
CR 2025/14 SPC Global Ltd - scrip for scrip roll-over
 

ATO Fact sheets
Category B players of WAFL clubs - taxation of match payments Fact sheets for individuals
 

5 February 2025
 

Rulings
CR 2025/6 Fleetsu Pty Ltd - Fleetsu Vehicle Logbook System for car logbook and odometer records
CR 2025/7 QANTM Intellectual Property Limited - scheme of arrangement and special dividend
 

3 February 2025
 

interpretation NOW!
Episode 116
 

30 January 2025
 

Practice statements
PS LA 2004/3 (GA) – Update Valuation of goods taken from trading stock for private use by sole traders or partners in a partnership
PS LA 2005/19 – Update Approved forms
PS LA 2006/16 – Update GST-free exports - the Commissioner's discretion to extend the time to export
PS LA 2011/18 – Update Enforcement measures used for the collection and recovery of tax-related liabilities and other amounts
 

29 January 2025
 

Rulings
CR 2025/3 Australian Cricketers' Association - employment termination payment
CR 2025/4 Boral Limited - compulsory acquisition - exchange of shares for shares in SGH Limited
CR 2025/5 Boral Limited - off-market takeover - exchange of shares for shares in SGH Limited
 

24 January 2025
 

Practice statements
PS LA 2014/2 – Update Administration of transfer pricing penalties for income years commencing on or after 29 June 2013
PS LA 2015/3 – Update Approval process for the application of subsections 815-130(2) to 815-130(4) of the Income Tax Assessment Act 1997
PS LA 2016/1 – Update Transfer pricing adjustments with potential customs implications
PS LA 2016/2 – Update Administration of scheme penalties arising from the application of Subdivision 815-A for income years which started on or after 1 July 2004 and before 1 July 2012
 

23 January 2025
 

Practice statements
PS LA 2014/3 - Update Simplifying transfer pricing record keeping
 

22 January 2025
 

Practice statements
PS LA 2001/8 ATO interpretative decisions
PS LA 2005/7 Substantiating an individual's work-related expenses
 

17 January 2024

Synthesised texts of the MLI and Australia's tax treaties
Papua New Guinea Synthesised text of the MLI and the Agreement between the Government of Australia and the Independent State of Papua New Guinea for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
 

16 January 2025
 

Practice statements
PS LA 2012/2 – Update Change of trustee
PS LA 2021/2 – Update The ATO's administrative approach to the extension of the Commissioner's discretion to retain tax refunds
 

15 January 2025
 

Rulings
CR 2025/1 AFL Players' Association Limited – employment termination payment
CR 2025/2 DBG Global Enterprises Pty Ltd – customer equity scheme
 

Notices
GSTD 2024/2ER1 – Erratum Goods and services tax: is the supply of a burial right in respect of a public cemetery subject to GST?
 

Decision impact statements
2020/6932 – Update Merchant and Commissioner of Taxation [2024] AATA 1102
 

Practical compliance guidelines
PCG 2025/D1 Fees for personal financial advice paid from member accounts by superannuation funds – apportioning the deduction and pay as you go withholding obligations
 

24 December 2024
 

Legislative instrument
F2024L01729 Income Tax Assessment (Build to Rent Developments) Determination 2024
 

19 December 2024
 

Practice statements
PS LA 2011/5 – Update Recovery of administrative overpayments
PS LA 2011/30 – Update Remission of administrative penalties relating to schemes imposed by subsection 284-145(1) of Schedule 1 to the Taxation Administration Act 1953
PS LA 2013/5 – Update Collection of consolidated group liabilities
PS LA 2013/6 – Update Collection from goods and services tax (GST) groups, GST joint ventures and other entities of debts arising from indirect tax laws
 

Legislative instrument
F2024L01713 Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024
 

Guidance – update
Guide to independent data testing by third-party advisers
 

interpretation NOW!
Episode 115
 

18 December 2024

Synthesised texts of the MLI and Australia's tax treaties
Mexico Synthesised text of the MLI and the Agreement between the Government of Australia and the Government of the United Mexican States for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
 

12 December 2024
 

Practice statements
PS LA 2024/1 – New Suspected fraud involving unconnected third parties
PS LA 2012/1 – Update Engaging Tax Counsel Network on tax technical issues
PS LA 2011/20 – Update Payment and credit allocation
PS LA 2008/11 – Withdrawn Suspected fraud by a third party or tax practitioner
 

11 December 2024
 

Rulings
CR 2024/76 APM Human Services International Limited - scrip for scrip roll-over
CR 2024/77 Toyota Motor Corporation Australia Limited - Toyota Halo system in conjunction with the Data Communication Module hardware for car logbook and odometer records
CR 2024/78 Vertical Telecoms Pty Limited - buy-back of employee shares acquired with a limited recourse loan
PR 2024/20 ING Bank (Australia) Limited - Orange Everyday Round Up to Charity
 

Determinations
TD 2024/D3 Income tax: Division 7A - does section 109U of the Income Tax Assessment Act 1936 only apply to arrangements where a private company gives a guarantee to another private company?
 

Draft amendments
TR 2004/18DC Income tax: capital gains: application of CGT event K6 (about pre-CGT shares and pre-CGT trust interests) in section 104-230 of the Income Tax Assessment Act 1997
 

Notices
TR 2023/4A1 - Addendum Income tax: pay as you go withholding - who is an employee?
 

Taxpayer alerts
TA 2024/2 Arrangements to circumvent Division 7A of the Income Tax Assessment Act 1936 through the guaranteeing by private companies of third-party loans
 

Decision impact statements
S170/2023 Automotive Invest Pty Limited v Commissioner of Taxation [2024] HCA 36
 

Practical compliance guidelines
PCG 2017/2 - Update Simplified transfer pricing record-keeping options
 

10 December 2024
 

Taxpayer alerts
TA 2024/1 Early stage investor tax offset claimed using circular financing arrangements
 

5 December 2024
 

Practice statements
PS LA 2011/11 – Update Refunds of certain pay as you go withholding amounts
PS LA 2011/22 – Update Commissioner's discretion to retain a refund
PS LA 2012/6 – Withdrawn Exercise of Commissioner's discretion to retain a refund
 

4 December 2024
 

Rulings
TR 2024/D3 Income tax: aspects of the third party debt test in Subdivision 820-EAB of the Income Tax Assessment Act 1997
MT 2024/1 Miscellaneous tax: time limits for claiming an input tax or fuel tax credit
 

Determinations
GSTD 2024/2 Goods and services tax: is the supply of a burial right in respect of a public cemetery subject to GST?
 

Notices
CR 2013/25A2 - Addendum Goods and services tax: the GST treatment of fees and charges imposed by NSW councils in relation to cemeteries, facilities, leases, legal services, libraries and sales
PR 2023/19A1 - Addendum Fringe benefits tax consequences for employers under an Origin electric vehicle subscription agreement
 

Decision impact statements
2022/7426 Came and Commissioner of Taxation [2023] AATA 3951
 

Practical compliance guidelines
PCG 2024/D3 - Update Restructures and the thin capitalisation and debt deduction creation rules - ATO compliance approach
PCG 2024/D4 Capital raised for the purpose of funding franked distributions - ATO compliance approach
 

3 December 2024
 

interpretation NOW!
Episode 114