Private ruling: Assessable income
Ruling period: Year ending 30 June 2011 | Year ending 30 June 2012 | Year ending 30 June 2013 | Year ending 30 June 2014 | Year ending 30 June 2015
Date scheme commenced: 1 July 2010

Ruling: Q1: Do dividends or other distributions received from holding shares or securities which are the trading stock of a business activity constitute assessable income of that business activity for the purposes of Division 35 of the Income Tax Assessment Act 1997 (ITAA 1997)? | A1: 


Relevant legislative provisions: Income Tax Assessment Act 1997 - Division 35

Reasons for decision: Summary: Dividends and other distributions received in relation to shares and securities held as trading stock of a share trading business are received as a direct result of holding the trading stock and would not be considered a separate business activity. Therefore, the assessable income of a business activity of share trading would include dividends and other distributions received from shares and securities held as trading stock of the business for the purposes of Division 35 of the ITAA 1997.

Please check this edited version to be sure that there are no details remaining that you think may allow you to be identified. Contact us at the address given in the fact sheet if you have any concerns. | Relevant facts: You conduct a business of trading in securities (shares and options). | You implement a range of trading and hedging strategies. | Generally, shares and securities which you hold as trading stock are purchased and sold within a 12 month period, although not necessarily within the same tax year. | As part of your trading strategies, you trade in shares both with and without an entitlement to dividends and can receive dividends on shares held as trading stock of your business activity. | You also hold some shares as long term investments which are not included in your trading stock.