Private ruling: Personal security provided during COVID-19
Date of advice: 5 June 2023
Published: 31 July 2023

Ruling: Q1: Is the provision of security at the sites as outlined in the ruling application a fringe benefit for the purpose of section 136(1) of the Fringe Benefits Tax Assessment Act 1986 (FBTAA) ? | A1: Yes. | Q2: If the provision of security at the sites is a fringe benefit, can the taxable value be reduced due to the operation of the 'otherwise deductible' rule under section 52 of the FBTAA? | A2: No.




Subject: Personal security provided during COVID-19: To protect the privacy and commercial in-confidence components of this private binding ruling, the following summary is provided. | The taxpayer sought a ruling in regard to whether personal security provided during Covid-19 would be a fringe benefit for the purpose of subsection 136(1) of the Fringe Benefits Tax Assessment Act 1986 (FBTAA)?