Notice of Rulings 11 December 2024 The Commissioner of Taxation, Rob Heferen, 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 2024/76 APM Human Services International Limited – scrip for scrip roll-over This Ruling sets out the income tax consequences for the holders of ordinary shares in APM Human Services International Limited who disposed of their ordinary shares to Ancora TopCo Ltd on 10 October 2024. This Ruling applies to shareholders specified in the Ruling from 1 July 2024 to 30 June 2025. 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 This Ruling sets out the fringe benefits tax consequences for users of the reports generated by the Toyota Halo system, using the Data Communication Module hardware, for car logbook and odometer records. This Ruling applies to employers specified in the Ruling from 1 April 2024 to 31 March 2028. CR 2024/78 Vertical Telecoms Pty Limited – buy-back of employee shares acquired with a limited recourse loan This Ruling sets out the income tax consequences for shareholders in Vertical Telecoms Pty Limited who acquired Class A shares under the employee incentive arrangement described in the Ruling and who subsequently disposed of those shares in the buy-back of shares described in the Ruling. This Ruling applies to shareholders specified in the Ruling to the income year in which the buy-back occurs. PR 2024/20 ING Bank (Australia) Limited – Orange Everyday Round Up to Charity This Ruling sets out the income tax consequences for individuals who hold an ING Bank (Australia) Limited Orange Everyday or Orange Everyday Youth bank account and activate the Round Up to Charity feature. This Ruling applies from 1 July 2024 to Account Holders specified in the Ruling who have activated the Round Up to Charity feature from 1 July 2024 until 30 June 2027. NOTICE OF ADDENDUM Ruling number Subject Brief description TR 2023/4 Income tax: pay as you go withholding – who is an employee? This Addendum amends TR 2023/4 to include guidance in Appendix 2 of the Ruling on when a person is considered to be an 'employee' under section 12 of the Superannuation Guarantee (Administration) Act 1992 (SGAA). Appendix 2 of the Ruling: • assists the community by confirming the ATO's view in light of developments in case law in the context of the SGAA since SGR 2005/1W Superannuation guarantee: who is an employee? (withdrawn) was last updated • consolidates the ATO's view in respect of the common law definition of employee contained in SGR 2005/1 (withdrawn) and TR 2023/4 • provides a holistic ATO view of the common law meaning of employee and extended meaning of the word as contained in the SGAA. This Addendum applies both before and after its date of issue.