COMMISSIONER OF TAXATION

The Commissioner of Taxation, Chris Jordan, gives notice of the following Rulings, copies of which can be obtained from Branches of the Australian Taxation Office or at http://law.ato.gov.au.

CR 2015/24

Income tax:  Calliden Group Limited Scheme of Arrangement and Special Dividend

The Ruling sets out the Commissioner’s position for ordinary shareholders of Calliden Group Limited.

The Ruling applies from 1 July 2014 to 30 June 2015.

CR 2015/25

Income tax:  Calliden Group Limited Scheme of Arrangement - Special Dividend - Participants of the Calliden Group Limited Incentive Rights Plan

The Ruling sets out the Commissioner’s position for all employees of Calliden or its wholly owned subsidiaries.

The Ruling applies from 1 July 2014 to 30 June 2015.

PR 2015/3

Income tax:  deductibility of interest in relation to investment in units in the Macquarie Flexi 100 Trust issued on or before 30 June 2018 – Flexi Professional

The Ruling sets out the Commissioner’s position on investment in the Macquarie Flexi 100 Trust using a limited recourse loan made by Macquarie Specialist Investments Lending Limited and the grant of put options over the investment by the Loan Provider.

The Ruling applies prospectively from 1 April 2015, the date it is published.

 

MT 2008/1

Penalty relating to statements:   meaning of reasonable care, recklessness and intentional disregard

The Addendum amends Miscellaneous Taxation Ruling MT 2008/01 to take into account:

  • the withdrawal of Law Administration Practice Statement PS LA 2006/2 and its replacement with Law Administration Practice Statements PS LA 2012/4 and 2012/5
  • that the administrative penalty contained in Division 284 of Schedule 1 to the Taxation Administration Act 1953 applies in relation to Petroleum Resource Rent Tax matters, and
  • the repeal of the Minerals Resource Rent Tax (MRRT).

 The Addendum applies on and from 1 October 2014.

MT 2008/2

Shortfall penalties:  administrative penalty for taking a position that is not reasonably arguable

 

The Addendum amends Miscellaneous Taxation Ruling MT 2008/02 to take into account:

  • the withdrawal of Law Administration Practice Statement PS LA 2006/2 and its replacement with Law Administration Practice Statements PS LA 2012/4 and 2012/5, and
  • the repeal of the Minerals Resource Rent Tax (MRRT).

The Addendum applies on and from 1 October 2014.

MT 2011/1

Miscellaneous taxes:  application of penalties and interest charges to the Commonwealth, States, Northern Territory and Australian Capital Territory

The Addendum amends Miscellaneous Taxation Ruling MT 2011/1 to take into account:

  • the withdrawal of Law Administration Practice Statement PS LA 2006/2 and its replacement with Law Administration Practice Statements PS LA 2012/4 and 2012/5
  • that the administrative penalty contained in Division 284 of Schedule 1 to the Taxation Administration Act 1953 applies in relation to Petroleum Resource Rent Tax matters, and
  • the repeal of the Minerals Resource Rent Tax (MRRT).

The Addendum applies on and from 1 October 2014.

MT 2012/3

Administrative penalties:  voluntary disclosures

The Addendum amends Miscellaneous Taxation Ruling MT 2012/3 to take into account:

  • the withdrawal of Law Administration Practice Statement PS LA 2006/2 and its replacement with Law Administration Practice Statements PS LA 2012/4 and 2012/5.
  • the repeal of the Minerals Resource Rent Tax (MRRT).

The Addendum applies on and from 1 October 2014.