Notice of Rulings 22 November 2023 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 CR 2023/61 Argo Investments Limited – dividend substitution share plan This Ruling sets out the income tax consequences of Argo Investments Limited shareholders electing to receive shares in lieu of dividends under the Argo Investments Limited Dividend Substitution Share Plan. The Ruling applies to shareholders specified in the Ruling from 1 July 2023 to 30 June 2028. CR 2023/62 Argo Global Listed Infrastructure Limited – dividend substitution share plan This Ruling sets out the income tax consequences for shareholders of Argo Global Listed Infrastructure Limited who elect to receive shares in lieu of dividends under the Argo Global Listed Infrastructure Limited Dividend Substitution Share Plan. The Ruling applies to the shareholders specified in the Ruling from 1 July 2023 to 30 June 2028. CR 2023/63 Carbon Revolution Limited – employee share scheme – exchange of shares for Carbon Revolution plc shares This Ruling sets out the income tax consequences for employees of Carbon Revolution Limited who acquired ordinary shares in Carbon Revolution Limited through the Tax Exempt Employee Share Plan which were subsequently cancelled in exchange for shares in Carbon Revolution plc on 3 November 2023. The Ruling applies to shareholders specified in the Ruling from 1 July 2020 to 30 June 2024. CR 2023/64 Sunland Group Limited – return of capital This Ruling sets out the income tax consequences for shareholders of Sunland Group Limited who receive a return of capital payment on 1 November 2023. The Ruling applies to shareholders specified in the Ruling from 1 July 2023 to 30 June 2024. PR 2023/24 Allianz Guaranteed Income for Life This Ruling sets out the income tax consequences for specified entities who receive specified payments from the Allianz Guaranteed Income for Life life policy to be offered by Allianz Australia Life Insurance Limited under the product disclosure statement. The Ruling applies to the entities specified in the Ruling that enter into a policy from 24 November 2023 until 30 June 2026. TD 2023/6 Income tax: tax incentives for early stage investors: what is an 'expense' that is 'incurred' for the early stage test? This Determination clarifies the expenses taken into account in determining whether a company meets the requirements of an early stage innovation company for its investors to access the tax incentives. The Determination applies to years of income commencing both before and after its date of issue. TD 2023/7 Income tax: value of goods taken from stock for private use for the 2023–24 income year This Determination provides an update of amounts that the Commissioner will accept as estimates of the value of goods taken from trading stock for private use by taxpayers in named industries. The Determination applies to the 2023–24 income year. NOTICE OF ADDENDUM Ruling number Subject Brief description PR 2019/5 Income tax: taxation consequences of investing in the Westpace Protected Equity Loan This Ruling is amended to incorporate the application of subsections 82KZM(1A) and 82KZMA(2A) of the Income Tax Assessment Act 1936. This Addendum applies before and after its date of issue.