Private ruling: Capital gains tax
Published: April 2015
Ruling period: Year ending 30 June 2015
Date scheme commenced: 1 July 2014

Ruling: Q1: Will a capital gains tax (CGT) event occur if the account designations of the shares are changed? | A1: No

Relevant facts and circumstances: This ruling is based on the facts stated in the description of the scheme that is set out below. If your circumstances are materially different from these facts, this ruling has no effect and you cannot rely on it. The fact sheet has more information about relying on your private ruling. You own a share portfolio of shares. New account designations will be added to the shares. The account designations will assist with identification of the 'sets' of shares. All shares within the portfolio will remain under the same TFN. No off market transfer is required to effect the share account designations. You are a discretionary trust.

Relevant legislative provisions: Income Tax Assessment Act 1997 Section 104-10

Reasons for decision: Summary: CGT event A1 occurs when a change of ownership of a CGT asset occurs from you to another entity. However CGT event A1 will not occur if you cease being the legal owner of the asset but continue to be the beneficial owner. In this case, it is proposed to change add new account designations to the shares. There will be no change in legal ownership of the shares; the account designations will enable identification of the shares. As the legal ownership of the shares will not change, there will be no CGT event A1. No other CGT event is relevant to your circumstances.