What this ruling covers
The Australian Taxation Office has issued Product Ruling PR 2026/19. The ruling sets out the income tax consequences for Australian residents who purchase, are assigned, or receive benefits under the Swiss Sure Insurance Limited Unit-Linked Life Insurance Global policy.
Who the ruling applies to
The ruling applies to policyholders and beneficiaries who are Australian tax residents at any point between 1 September 2026 and 30 June 2029.
Key tax outcomes confirmed by the ruling
Eligible policy status
The ruling confirms the policy is an eligible policy under section 26AH of the Income Tax Assessment Act 1936.
Assessable surrender proceeds
The earnings-linked portions of surrender proceeds are assessable as bonuses when received within 10 years of the first premium being paid.
Capital gains and losses
Capital gains or losses arising from surrender proceeds or death benefits are disregarded under the Income Tax Assessment Act 1997.
Anti-avoidance provisions
The ruling confirms that Part IVA anti-avoidance provisions will not apply, provided the scheme is carried out exactly as described in the ruling.
What the ruling does not cover
This ruling does not cover:
- Superannuation fund compliance
- Foreign exchange gains or losses
- Deductibility of fees
- Tax consequences for non-residents
Key actions
- Australian tax residents who have purchased, been assigned, or received benefits under the Swiss Sure Unit-Linked Life Insurance Global policy on or after 1 September 2026 are required to confirm with a tax adviser whether this ruling applies to their specific situation.
- The 10-year eligible period under section 26AH determines when surrender proceeds become assessable - if surrender proceeds are received within 10 years of the first premium, the earnings portion is assessable income. Confirming whether this period applies to a specific policy is a step the ruling identifies for policyholders.
- If annual premiums increase by more than 25% compared to the previous year, the 10-year eligible period resets to the start of the year the increase occurred. The ruling identifies this as a factor to consider before increasing premiums.
- Trustees of superannuation funds are noted in the ruling as receiving no assurance about compliance with the Superannuation Industry (Supervision) Act 1993 from this ruling. Separate legal advice is identified as applicable before investing.
- The ruling can be relied upon only where no changes to the scheme or legislation have occurred since 30 September 2026. Changes may affect whether the ruling applies.
This is a plain-English summary for information only, not legal or compliance advice. Always check the official source or consult a qualified professional.