Notice of Rulings 28 July 2021 (Cth)

Notice of Rulings 28 July 2021

The Commissioner of Taxation, Chris Jordan, gives notice by notifiable instrument under subsection 358-5(4) of Schedule 1 to the Taxation Administration Act 1953 of the following public rulings, copies of which can be obtained from ato.gov.au/law

NOTICE OF RULINGS Ruling number Subject Brief description LCR 2021/2 Non-arm's length income – expenditure incurred under a non‑arm's length arrangement This Ruling provides legislative guidance and greater certainty to taxpayers to clarify how the amendments to section 295‑550 of the Income Tax Assessment Act 1997 operate in a scheme where the parties do not deal with each other at arm's length and the trustee of a complying superannuation entity incurs non‑arm's length expenditure (or where expenditure is not incurred) in gaining or producing ordinary or statutory income. The amendments apply in relation to income derived in the 2018–19 income year and later income years, regardless of whether the scheme was entered into before 1 July 2018. This Ruling applies from 1 July 2018. CR 2021/49 Cassini Resources Limited – demerger and scrip for scrip roll-over This Ruling sets out the tax consequences for holders of units in Cassini Resources Limited that exchanged their units for units in OZ Minerals Limited. This Ruling applies from 1 July 2020 to 30 June 2021. CR 2021/50 Woolworths Group Limited – demerger of Endeavour Group Limited This Ruling sets out the tax consequences of the demerger of Endeavour Group Limited by Woolworths Group Limited, which was implemented on 1 July 2021. This Ruling applies from 1 July 2020 to 30 June 2022. CR 2021/51 Australian Vintage Ltd – return of capital and share consolidation This Ruling sets out the tax consequences of the return of share capital by Australian Vintage Ltd and the consolidation of ordinary shares in Australian Vintage Ltd. This Ruling applies from 1 July 2021 to 30 June 2022. CR 2021/52 Intelligent Investor Australian Growth Fund – scrip for scrip roll-over This Ruling sets out the tax consequences for holders of units in the Intelligent Investor Australian Growth Fund that exchanged their units for units in the Intelligent Investor Australian Equity Growth Fund. This Ruling applies from 1 July 2020 to 30 June 2021.