The ATO on Wed 29.1.2.014, issued the following Class Rulings:

  • CR 2014/10: Share consolidation and in specie distribution: Macquarie Group Limited. It applies from 1 July 2013 to 30 June 2014. Broadly, the Ruling states that the dividend component of the distribution must be included in the assessable income of the shareholder.
  • CR 2014/11: Demerger of Orora Limited by Amcor Limited. It applies from 1 July 2013 to 30 June 2014. Among other things, the Ruling states that eligible shareholders can choose demerger roll-over relief under s 125-55(1) of the ITAA 1997.
  • CR 2014/12: Demerger of Recall Holdings Limited by Brambles Limited. It applies from 1 July 2013 to 30 June 2014. The Ruling broadly states that a shareholder can choose demerger roll-over to disregard any capital gain made when CGT event G1 happened in relation to their shares.
  • CR 2014/13: Format of mobile phone invoice as evidence for donations to World Wide Fund for Nature via SMS. It applies from 1 February 2014 until 30 June 2019. The Ruling states the Commissioner accepts the mobile invoice as satisfying the requirements under s 30-228 provided the invoice identifies the date of the gift, the description, and the quantum of the gift.
  • CR 2014/14: Macquarie Group Employee Retained Equity Plan: share consolidation and in specie distribution: Macquarie Group Limited. It applies from 1 July 2013 to 30 June 2014. The Ruling states, among other things, that the in specie distribution of securities will not cause an ESS deferred taxing point under s 83A-115 in respect of selected shareholders.

[LTN 18, 29/1/14]