Notice of Rulings 9 February 2022 (Cth)

Notice of Rulings 9 February 2022 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 TD 2022/1 Income tax: commercial debt forgiveness – does the exclusion for debts forgiven for reasons of natural love and affection require that the creditor be a natural person? This Ruling provides that paragraph 245‑40(e) of the Income Tax Assessment Act 1997 excludes a debt forgiven for reasons of natural love and affection from the application of the commercial debt forgiveness provisions, where the creditor is a natural person. CR 2022/5 AIA Australia Limited – provision of free membership, allocation of points, and free or discounted goods and services to members of a health and wellness program This Ruling sets out fringe benefits tax consequences of the provision of free membership of a health and wellness program, the allocation of points, and receipt of free or discounted goods and services, to members of the AIA Vitality Program. This Ruling applies from 1 April 2020 to 31 March 2024. CR 2022/6 Bingo Industries Limited – scheme of arrangement and special dividend This Ruling sets out the income tax consequences of the special dividend paid on 28 July 2021 and the Scheme of Arrangement implemented by Bingo Industries Limited on 5 August 2021. This Ruling applies from 1 July 2021 to 30 June 2022. CR 2022/7 RAM Australia Retail Property Fund This Ruling sets out the income tax consequences for the unit holders of the RAM Australia Retail Property Fund who were entitled to receive a return of capital from the Trustee of the RAM Australia Retail Property Fund which was satisfied by those unit holders acquiring units in the RAM Australia Medical Property Fund, followed by the stapling of the RAM Australia Retail Property Fund units and RAM Medical Fund units. – return of capital and formation of a stapled security This Ruling applies from 1 July 2021 to 30 June 2022. CR 2022/8 RAM Australia Medical Property Fund – return of capital and formation of a stapled security This Ruling sets out the income tax consequences for the unit holders of the RAM Australia Medical Property Fund who were entitled to receive a return of capital from the Trustee of RAM Medical Fund which was satisfied by those unit holders acquiring units in the RAM Australia Retail Property Fund, followed by the stapling of the RAM Medical Fund units and RARPF units. This Ruling applies from 1 July 2021 to 30 June 2022. CR 2022/9 Afterpay Limited – scrip for scrip roll‑over This Ruling sets out the income tax consequences for the holders of ordinary shares in Afterpay Limited in relation to the acquisition of those shares by Lanai (AU) 2 Pty Ltd on 1 February 2022. This Ruling applies from 1 July 2021 to 30 June 2022. CR 2022/10 Chalice Mining Limited – demerger of Falcon Metals Ltd This Ruling sets out the income tax consequences of the demerger of Falcon Metals Ltd by Chalice Mining Limited which was implemented on 15 December 2021. This Ruling applies from 1 July 2021 to 30 June 2022.