CR 2013/77 – FBT: frequent flyer points under LM High Flyers program – Toyota Dealers High Flyers Incentive Scheme provides property benefits [41]

The ATO, on Wed 30.10.2013, issued Class Ruling CR 2013/77 (FBT: rewards received by an employee under the LM High Flyers incentive program). The Ruling applies to employers, appointed under an agreement with Toyota Motor Corporation Australia Limited to be authorised dealers, who enable employees to participate in the LM High Flyers incentive program (the…

PR 2013/17-20 – Timber and almond projects; Westpac Protected Equity Loan [39]

The ATO on Wed 23.10.2013, issued the following Product Rulings: PR 2013/17 (AgriWealth 2014 Softwood Timber Project). According to this Ruling, a Grower can claim deductions for specified amounts (eg establishment services fees, etc) when they are paid to the Manager. It applies prospectively from Wed 23.10.2013, the date it was published. PR 2013/18 (Macquarie…

CR 2013/75 – The Imperial Tobacco Australia Limited Voluntary Early Retirement Scheme [38]

The ATO on Wed 16.10.2013, issued Class Ruling CR 2013/75 (The Imperial Tobacco Australia Limited Voluntary Early Retirement Scheme (VRS)). It applies from Wed 16.10.2013 to 28 February 2014. Broadly, the Ruling states that the early retirement scheme to be implemented is an early retirement scheme for the purposes of s 83-180 of the ITAA 1997. [LTN 200,…

TD 2013/21 – Tax consolidated group reporting – inconsistent methodologies for converting foreign currencies don’t qualify [36]

This TD, released on Wed 23.10.2013, says that a consolidated special purpose financial report of a head company of a tax consolidated group cannot satisfy clause 1.1 of Sch 2 to the Income Tax Assessment Regulations 1997 where transactions within the same category are translated using inconsistent methodologies. Clause 1.1 of Sch 2 to the Regulations allows…

TR 2013/6 – FBT – expenditure subject to Div 35 non-commercial loss deferral cannot give rise to a ‘once only deduction’ for ‘otherwise deductible’ purposes [34]

This Ruling, released on Wed 23.10.2013, sets out the Commissioner’s views on whether a “once only deduction” arises in calculating the taxable value of an “external expense payment fringe benefit” under s 24 of the Fringe Benefits Tax Assessment Act 1986 (FBTAA) where the expenditure associated with that fringe benefit would be subject to the loss…