Class Ruling CR 2020/14

What this ruling is about: 1. This Ruling sets out the circumstances in which the logbook report and the odometer reading report that the SmarTrak Aust Pty Ltd (PoolCar) booking system produces satisfies the legislative requirements for the purpose of calculating the taxable value of a car fringe benefit using the cost basis method. 2. Broadly, sections 10A and 10B of the Fringe Benefits Tax Assessment Act 1986 [1] allow an employer to reduce the operating cost of a car for business journeys that are undertaken in the car during the period in which the car was held (either by the employer or another person). Such a reduction can only occur where certain conditions are met. 3. Full details of the PoolCar booking system are set out in paragraphs 20 to 40 of this Ruling. Note: By issuing this Ruling, the ATO is not endorsing this product. Potential purchasers/users must form their own view about the product. Who this Ruling applies to 4. This Ruling applies to you if you are an employer who uses the PoolCar booking system to keep car logbook records and odometer records for the purposes of calculating the taxable value of a car fringe benefit using the cost basis method. When this Ruling applies 5. This Ruling applies from 1 April 2019 to 31 March 2024. Background to legislative requirements 6. Section 10 allows employers to elect to calculate the taxable value of a car fringe benefit using the cost basis method (operating cost method). 7. Where the election is made, the taxable value of the car fringe benefit using the operating cost method is calculated according to the formula in subsection 10(2). 8. In accordance with this formula, an employer intending to claim a reduction in the operating cost of a car, on account of business journeys undertaken during the holding period, must meet the requirements of either section 10A (if the year is a 'logbook year of tax' (as defined in subsection 136(1)) or section 10B (if the year is not a 'logbook year of tax'), as applicable. 9. Section 10A requires that in a logbook year: 10. Section 10B requires that in a non-logbook year: 11. A year in which the PoolCar booking system is used will be a 'logbook year of tax' if: 12. The subsequent four years will be a 'non-logbook year of tax' if either dot points in paragraph 11 of this Ruling applies to the first year. Logbook records 13. The PoolCar booking system 'Logbook report' is a document which satisfies the definition of 'log book records' in subsection 136(1), as over the time the fringe benefits tax (FBT) logbook reports are being kept [4] : 14. However, the PoolCar booking system 'Logbook report' is not a document which satisfies the definition of 'log book records' in subsection 136(1) if: Odometer records 15. The PoolCar booking system 'Odometer reading report' satisfies the definition of 'odometer records' in subsection 136(1) [5] as it provides details of the odometer reading for the car at the start of the first recorded journey and also the odometer reading for the car at the end of the last recorded journey that were undertaken during each report period. Satisfying the requirements of section 10A in a logbook year of tax 16. An employer satisfies the requirement in section 10A and is entitled to claim a reduction of operating costs in a logbook year of tax if the PoolCar booking system is used continuously for: 17. If the PoolCar booking system: then the employer satisfies the requirement in section 10A and is entitled to claim a reduction of operating costs in a logbook year of tax provided the employer: Satisfying the requirements of section 10B in a non-logbook year of tax 18. An employer satisfies the requirement in section 10B and is entitled to claim a reduction of operating costs in a non-logbook year of tax if the PoolCar booking system is used continuously for the whole of the holding period. 19. An employer in a non-logbook year of tax who has used the PoolCar booking system in one of the previous four FBT years continuously for an 'applicable logbook period' but: satisfies the requirements in section 10B and will be entitled to claim a reduction of operating costs of the car on account of business journeys undertaken in the car during the holding period provided the employer: 20. The following description of the scheme is based on information provided by the applicant. If the scheme is not carried out as described, this Ruling cannot be relied upon. 21. The PoolCar booking system is a suite of mobility booking systems for organisations with shared vehicles. 22. The PoolCar booking system consists of an online booking calendar that is updated in real time and can be accessed from a web browser, smartphone or tablet application. The system operates like a shared calendar - on a given time and date, the system provides details of vehicles that are available from nominated locations. It is designed to be used for the entire FBT year for each vehicle registered in the system. 23. Car and employee registration are required with secure login and password features. Employees once logged in, can search for available cars by motor pool location, body type (for example, sedan, wagon, dual cab), transmissions and accessories such as whether the vehicle is fitted with an e-tag. 24. Bookings are the reservation for a vehicle. The car booking system captures when the car was taken and returned with the 'Check Out/In' feature. Car keys are managed via a 'key cabinet' in a central location and can only be taken by the employee when they 'Check Out' that particular car. The booking screen captures details including: 25. On 'Check In', the system captures vital data from the driver such as the odometer reading, parking location, overnight garaging, fuel level, business-use percentage for that trip and if there is any damage that needs looking at. 26. The Check Out/In process can be done via the key cabinet, smartphone or the online booking system at the Check Out/In tab. The Telematics tab gives a pin drop of where the vehicle is located. 27. GPS tracking is enabled by way of an In-car device that is installed in the car to capture journey information. The In-car device is a GPS device that can monitor the position of the car so as to determine the car's journeys. It also records the start and stop times of the journeys and calculates the distance travelled in each of the journeys. Engine start and end are matched to bookings and kilometres travelled for that trip and are then updated into the logbook report for the driver and the vehicle. 28. Recorded data is saved onto the device memory with identifiers including the time and date of each capture. The recorded data is then automatically sent using a wireless mobile connection to the PoolCar system. 29. Should coverage on the mobile network not be available, the In-car device will automatically store the recorded data and periodically resend until successful. 30. Combining booking data with GPS telematics trip data allows for the accurate capture of odometer readings and other trip information. Booking data then flows through to the various system reports. 31. The PoolCar booking system can also be used where GPS tracking is not enabled in an employer's car fleet. In order to ensure capture of relevant odometer records, specific internal controls can be enabled if required. 32. The PoolCar booking system produces two specific reports to be used in conjunction with the operating cost basis of determining the taxable value of car benefits: Logbook report 33. The logbook report provides for the following details per vehicle booking: 34. When the PoolCar booking system is used for FBT record-keeping purposes, the option must be enabled to ensure it is compulsory for employees to complete the odometer reading, to capture the split between private and business and enter in a journey description at the time of making the journey or shortly thereafter. 35. The logbook report is produced in English and can be exported by way of Excel and comma-separated values (CSV) format. Odometer reading report 36. The odometer reading report lists all the PoolCar booking system registered vehicles and their odometer readings as at a specified date. 37. When a vehicle is added to the fleet, its details are recorded in the vehicle register along with the opening odometer reading. The vehicle's odometer reading can also be recorded as at 31 March each year and when a car is disposed of. 38. Odometer readings are obtained either by manual entry (paragraph 25 of this Ruling) or, where GPS telematics is enabled, determined by the In-car device. 39. The odometer reading report provides for the following details: 40. The odometer reading report is produced in English and can be exported by way of Excel and CSV format. Commissioner of Taxation 25 March 2020 © AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products). Not previously issued as a draft

Class of entities or scheme: 20. The following description of the scheme is based on information provided by the applicant. If the scheme is not carried out as described, this Ruling cannot be relied upon. 21. The PoolCar booking system is a suite of mobility booking systems for organisations with shared vehicles. 22. The PoolCar booking system consists of an online booking calendar that is updated in real time and can be accessed from a web browser, smartphone or tablet application. The system operates like a shared calendar - on a given time and date, the system provides details of vehicles that are available from nominated locations. It is designed to be used for the entire FBT year for each vehicle registered in the system. 23. Car and employee registration are required with secure login and password features. Employees once logged in, can search for available cars by motor pool location, body type (for example, sedan, wagon, dual cab), transmissions and accessories such as whether the vehicle is fitted with an e-tag. 24. Bookings are the reservation for a vehicle. The car booking system captures when the car was taken and returned with the 'Check Out/In' feature. Car keys are managed via a 'key cabinet' in a central location and can only be taken by the employee when they 'Check Out' that particular car. The booking screen captures details including: 25. On 'Check In', the system captures vital data from the driver such as the odometer reading, parking location, overnight garaging, fuel level, business-use percentage for that trip and if there is any damage that needs looking at. 26. The Check Out/In process can be done via the key cabinet, smartphone or the online booking system at the Check Out/In tab. The Telematics tab gives a pin drop of where the vehicle is located. 27. GPS tracking is enabled by way of an In-car device that is installed in the car to capture journey information. The In-car device is a GPS device that can monitor the position of the car so as to determine the car's journeys. It also records the start and stop times of the journeys and calculates the distance travelled in each of the journeys. Engine start and end are matched to bookings and kilometres travelled for that trip and are then updated into the logbook report for the driver and the vehicle. 28. Recorded data is saved onto the device memory with identifiers including the time and date of each capture. The recorded data is then automatically sent using a wireless mobile connection to the PoolCar system. 29. Should coverage on the mobile network not be available, the In-car device will automatically store the recorded data and periodically resend until successful. 30. Combining booking data with GPS telematics trip data allows for the accurate capture of odometer readings and other trip information. Booking data then flows through to the various system reports. 31. The PoolCar booking system can also be used where GPS tracking is not enabled in an employer's car fleet. In order to ensure capture of relevant odometer records, specific internal controls can be enabled if required. 32. The PoolCar booking system produces two specific reports to be used in conjunction with the operating cost basis of determining the taxable value of car benefits: | Logbook report: 33. The logbook report provides for the following details per vehicle booking: 34. When the PoolCar booking system is used for FBT record-keeping purposes, the option must be enabled to ensure it is compulsory for employees to complete the odometer reading, to capture the split between private and business and enter in a journey description at the time of making the journey or shortly thereafter. 35. The logbook report is produced in English and can be exported by way of Excel and comma-separated values (CSV) format. | Odometer reading report: 36. The odometer reading report lists all the PoolCar booking system registered vehicles and their odometer readings as at a specified date. 37. When a vehicle is added to the fleet, its details are recorded in the vehicle register along with the opening odometer reading. The vehicle's odometer reading can also be recorded as at 31 March each year and when a car is disposed of. 38. Odometer readings are obtained either by manual entry (paragraph 25 of this Ruling) or, where GPS telematics is enabled, determined by the In-car device. 39. The odometer reading report provides for the following details: 40. The odometer reading report is produced in English and can be exported by way of Excel and CSV format. Commissioner of Taxation 25 March 2020 © AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).

Ruling: 1. This Ruling sets out the circumstances in which the logbook report and the odometer reading report that the SmarTrak Aust Pty Ltd (PoolCar) booking system produces satisfies the legislative requirements for the purpose of calculating the taxable value of a car fringe benefit using the cost basis method. 2. Broadly, sections 10A and 10B of the Fringe Benefits Tax Assessment Act 1986 [1] allow an employer to reduce the operating cost of a car for business journeys that are undertaken in the car during the period in which the car was held (either by the employer or another person). Such a reduction can only occur where certain conditions are met. 3. Full details of the PoolCar booking system are set out in paragraphs 20 to 40 of this Ruling. Note: By issuing this Ruling, the ATO is not endorsing this product. Potential purchasers/users must form their own view about the product. | Who this Ruling applies to: 4. This Ruling applies to you if you are an employer who uses the PoolCar booking system to keep car logbook records and odometer records for the purposes of calculating the taxable value of a car fringe benefit using the cost basis method. | When this Ruling applies: 5. This Ruling applies from 1 April 2019 to 31 March 2024. | Background to legislative requirements: 6. Section 10 allows employers to elect to calculate the taxable value of a car fringe benefit using the cost basis method (operating cost method). 7. Where the election is made, the taxable value of the car fringe benefit using the operating cost method is calculated according to the formula in subsection 10(2). 8. In accordance with this formula, an employer intending to claim a reduction in the operating cost of a car, on account of business journeys undertaken during the holding period, must meet the requirements of either section 10A (if the year is a 'logbook year of tax' (as defined in subsection 136(1)) or section 10B (if the year is not a 'logbook year of tax'), as applicable. 9. Section 10A requires that in a logbook year: 10. Section 10B requires that in a non-logbook year: 11. A year in which the PoolCar booking system is used will be a 'logbook year of tax' if: 12. The subsequent four years will be a 'non-logbook year of tax' if either dot points in paragraph 11 of this Ruling applies to the first year. | Logbook records: 13. The PoolCar booking system 'Logbook report' is a document which satisfies the definition of 'log book records' in subsection 136(1), as over the time the fringe benefits tax (FBT) logbook reports are being kept [4] : 14. However, the PoolCar booking system 'Logbook report' is not a document which satisfies the definition of 'log book records' in subsection 136(1) if: | Odometer records: 15. The PoolCar booking system 'Odometer reading report' satisfies the definition of 'odometer records' in subsection 136(1) [5] as it provides details of the odometer reading for the car at the start of the first recorded journey and also the odometer reading for the car at the end of the last recorded journey that were undertaken during each report period. | Satisfying the requirements of section 10A in a logbook year of tax: 16. An employer satisfies the requirement in section 10A and is entitled to claim a reduction of operating costs in a logbook year of tax if the PoolCar booking system is used continuously for: 17. If the PoolCar booking system: then the employer satisfies the requirement in section 10A and is entitled to claim a reduction of operating costs in a logbook year of tax provided the employer: | Satisfying the requirements of section 10B in a non-logbook year of tax: 18. An employer satisfies the requirement in section 10B and is entitled to claim a reduction of operating costs in a non-logbook year of tax if the PoolCar booking system is used continuously for the whole of the holding period. 19. An employer in a non-logbook year of tax who has used the PoolCar booking system in one of the previous four FBT years continuously for an 'applicable logbook period' but: satisfies the requirements in section 10B and will be entitled to claim a reduction of operating costs of the car on account of business journeys undertaken in the car during the holding period provided the employer: 20. The following description of the scheme is based on information provided by the applicant. If the scheme is not carried out as described, this Ruling cannot be relied upon. 21. The PoolCar booking system is a suite of mobility booking systems for organisations with shared vehicles. 22. The PoolCar booking system consists of an online booking calendar that is updated in real time and can be accessed from a web browser, smartphone or tablet application. The system operates like a shared calendar - on a given time and date, the system provides details of vehicles that are available from nominated locations. It is designed to be used for the entire FBT year for each vehicle registered in the system. 23. Car and employee registration are required with secure login and password features. Employees once logged in, can search for available cars by motor pool location, body type (for example, sedan, wagon, dual cab), transmissions and accessories such as whether the vehicle is fitted with an e-tag. 24. Bookings are the reservation for a vehicle. The car booking system captures when the car was taken and returned with the 'Check Out/In' feature. Car keys are managed via a 'key cabinet' in a central location and can only be taken by the employee when they 'Check Out' that particular car. The booking screen captures details including: 25. On 'Check In', the system captures vital data from the driver such as the odometer reading, parking location, overnight garaging, fuel level, business-use percentage for that trip and if there is any damage that needs looking at. 26. The Check Out/In process can be done via the key cabinet, smartphone or the online booking system at the Check Out/In tab. The Telematics tab gives a pin drop of where the vehicle is located. 27. GPS tracking is enabled by way of an In-car device that is installed in the car to capture journey information. The In-car device is a GPS device that can monitor the position of the car so as to determine the car's journeys. It also records the start and stop times of the journeys and calculates the distance travelled in each of the journeys. Engine start and end are matched to bookings and kilometres travelled for that trip and are then updated into the logbook report for the driver and the vehicle. 28. Recorded data is saved onto the device memory with identifiers including the time and date of each capture. The recorded data is then automatically sent using a wireless mobile connection to the PoolCar system. 29. Should coverage on the mobile network not be available, the In-car device will automatically store the recorded data and periodically resend until successful. 30. Combining booking data with GPS telematics trip data allows for the accurate capture of odometer readings and other trip information. Booking data then flows through to the various system reports. 31. The PoolCar booking system can also be used where GPS tracking is not enabled in an employer's car fleet. In order to ensure capture of relevant odometer records, specific internal controls can be enabled if required. 32. The PoolCar booking system produces two specific reports to be used in conjunction with the operating cost basis of determining the taxable value of car benefits: | Logbook report: 33. The logbook report provides for the following details per vehicle booking: 34. When the PoolCar booking system is used for FBT record-keeping purposes, the option must be enabled to ensure it is compulsory for employees to complete the odometer reading, to capture the split between private and business and enter in a journey description at the time of making the journey or shortly thereafter. 35. The logbook report is produced in English and can be exported by way of Excel and comma-separated values (CSV) format. | Odometer reading report: 36. The odometer reading report lists all the PoolCar booking system registered vehicles and their odometer readings as at a specified date. 37. When a vehicle is added to the fleet, its details are recorded in the vehicle register along with the opening odometer reading. The vehicle's odometer reading can also be recorded as at 31 March each year and when a car is disposed of. 38. Odometer readings are obtained either by manual entry (paragraph 25 of this Ruling) or, where GPS telematics is enabled, determined by the In-car device. 39. The odometer reading report provides for the following details: 40. The odometer reading report is produced in English and can be exported by way of Excel and CSV format. Commissioner of Taxation 25 March 2020 © AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products). Not previously issued as a draft




What this Ruling is about | If this Ruling applies to you, and you correctly rely on it, we will apply the law to you in the way set out in this Ruling. That is, you will not pay any more tax or penalties or interest in respect of the matters covered by this Ruling. | Further, if we think that this Ruling disadvantages you, we may apply the law in a way that is more favourable to you.


Legislative references: FBTAA 1986 10 FBTAA 1986 10(2) FBTAA 1986 10A FBTAA 1986 10B FBTAA 1986 136(1) FBTAA 1986 162C FBTAA 1986 162G FBTAA 1986 162G(1) FBTAA 1986 162G(1)(a) FBTAA 1986 162G(1)(b) FBTAA 1986 162H(1) TAA 1953