Document ID: chunk:federal_register_of_legislation:F2024N00592:body:0:p1
Version: federal_register_of_legislation:F2024N00592
Segment Type: other
Provision Reference: 
Character Range: 0–4121

Notice of Rulings and Withdrawal of Rulings 3 July 2024
The Commissioner of Taxation, Rob Heferen, gives notice by notifiable instrument under subsection 358-5(4) of Schedule 1 to the Taxation Administration Act 1953 of the following public rulings, , and under subsection 358-20(1) of Schedule 1 to the Taxation Administration Act 1953 of the withdrawal of the following public ruling, copies of which can be obtained from ato.gov.au/law

NOTICE OF RULINGS
Ruling number      Subject                                                                                                                    Brief description
TD 2024/4          Income tax:  hybrid mismatch rules – application of certain aspects of the 'liable entity' and 'hybrid payer' definitions  This Determination sets out our view on 2 separate but related issues, whether:
                                                                                                                                                  * hypothetical income or profits within the tax base of a country can be used to identify a 'liable entity' or entities in the country for the purposes of section 832-325 of the Income Tax Assessment Act 1997, and
                                                                                                                                                  * a 'non-including country' for the purpose of subsection 832-320(3) of the 'hybrid payer' definition can be a jurisdiction other than the country where the payee of the relevant payment is located or resides.
                                                                                                                                              This Determination applies both before and after its date of issue.
CR 2024/36         National Australia Bank Limited – NAB Capital Notes 8                                                                      This Ruling sets out the income tax consequences for entities who subscribed for and acquired National Australia Bank Capital Notes 8 issued by National Australia Bank Limited.
                                                                                                                                              This Ruling applies from 1 July 2023 to 30 June 2035.
CR 2024/37         Calima Energy Limited – return of capital                                                                                  This Ruling sets out the income tax consequences for shareholders of Calima Energy Limited who received a return of capital payment of 12.63 cents per ordinary Calima share on 21 June 2024.
                                                                                                                                              This Ruling applies to shareholders specified in the Ruling from 1 July 2023 to 30 June 2024.
CR 2024/38         Best & Less Holdings Group Pty Limited – employee share scheme – disposal of shares                                        This Ruling sets out the income tax consequences for employees of Best & Less Group Holdings Pty Limited and its subsidiaries who participated in the Best & Less Group Holdings Limited Tax Exempt Share Plan who were subject to an off-market takeover by BBRC Admin 1 Pty Ltd.
                                                                                                                                              This Ruling applies to shareholders specified in the Ruling from 1 July 2021 to 30 June 2024.
CR 2024/39         EROAD Australia Pty Ltd – Fuel Tax Credits Solution                                                                        This Ruling sets out when the FTC Report generated from EROAD Australia Pty Ltd's Fuel Tax Credits Solution can be used as a record (but not the only record) for fuel tax credit record-keeping purposes.
                                                                                                                                              This Ruling applies to taxable fuel acquired on or after 1 July 2024 to 30 June 2026.
PR 2024/11         Utmost Executive Investment