Private ruling: CGT cost base
Published: January 2015
Ruling period: Year ended 30 June 2013
Date scheme commenced: 1 July 2012

Ruling: Question and Answer | Do you calculate the cost base of your assets from the day you cease to be a temporary resident but remain an Australian resident? | Yes

Relevant facts and circumstances: You arrived in Australia on a temporary resident visa. You became a permanent resident in the financial year ended 30 June 2013. You own CGT assets outside of Australia.

Relevant legislative provisions: Section 768-955 of the Income Tax Assessment Act 1997

Reasons for decision: Detailed Reasoning - Temporary residents and CGT: Normally, when a foreign resident becomes an Australian resident, a cost base applies for certain assets held by that person. This rule will not apply where the person is a temporary resident. Where a temporary resident ceases to be a temporary resident but remains an Australian resident (e.g. becomes a permanent resident), the first element of the cost base or reduced cost base of each CGT asset that is brought within the CGT net as a result of your change of residency status. The cost base is deemed to be the asset market value at the time you ceased to be a temporary resident. The CGT provisions will apply to the asset as if it had been acquired at that time.