Private ruling: Assessable income
Date of advice: 24 February 2026
Published: 20 April 2026
Ruling period: Income year ended 30 June 2025

Ruling: Q1: Is the interest income earned from the term deposits included in the Individuals' assessable incomes under section 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997)? | A1: No | Q2: Is the interest income earned from the term deposits included in the Company's assessable income under section 6-5 of the ITAA 1997? | A2: Yes

Relevant facts and circumstances: 1. The Individuals opened 2 term deposit accounts. Their intention was to invest funds belonging to their wholly owned Company, and for the accounts to be held in the Company's name. 2. However, due to an error made by the bank, both term deposit accounts were mistakenly opened in the joint personal names of the Individuals rather than in the Company's name. 3. The bank provided written confirmation that the accounts were opened in the incorrect name due to bank error. The bank acknowledges that the Individuals had instructed that the deposits be opened in the Company's name. 4. The letters confirm: a. The term deposit accounts were incorrectly opened in the Individual's personal names. b. The mistake occurred because the bank officer failed to check or verify the account details with the customers prior to processing the request. c. The error has since been corrected, and a new term deposit has been opened in the correct name.

Relevant legislative provisions: section 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997)