ATO Rulings & Determinations

The ATO has confirmed that time spent in Australia never counts as foreign service under section 23AG. The rule applies from the 2026-27 income year.

The ATO has finalised its update to TD 2012/8 on foreign service under section 23AG. Time spent in Australia cannot count as foreign service from 2026-27.

ATO Class Ruling CR 2026/73 confirms how income tax applies to termination payments from the Mechanical Electrical Redundancy Trust, covering the period 1 July

ATO Class Ruling CR 2026/74 confirms two Senetas Corporation return of capital payments are not dividends for income tax purposes. Details for shareholders.

ATO Class Ruling CR 2026/75 covers CGT treatment for Australian shareholders who exchanged African Gold Ltd shares for Montage Gold Corp shares on 29 April 2026

The ATO has updated TD 2012/8 to clarify which absences count as continuous foreign service under section 23AG of the Income Tax Assessment Act 1936.

ATO Product Ruling PR 2026/19 sets out income tax consequences for Australian residents holding the Swiss Sure Unit-Linked Life Insurance Global policy.

ATO Product Ruling PR 2026/20 sets out the income tax and CGT treatment of St. James's Place FAB and PAB bonds for Australian residents.

ATO Class Ruling CR 2026/69 confirms EROAD's FTC Report can be used as a fuel tax credit record, with conditions, for taxable fuel acquired 1 July 2026 to 30 Ju

The ATO has confirmed via Class Ruling CR 2026/70 that Commonwealth Teaching Scholarship payments are exempt from income tax for eligible full-time students.

The ATO has issued CR 2026/71 confirming SmarTrak's PoolCar booking system reports can satisfy FBT record-keeping requirements under the operating cost method.

ATO Class Ruling CR 2026/72 covers the tax treatment for Australian residents who exchanged Nova Minerals shares for NMC CDIs on 16 June 2026.

The ATO has withdrawn PR 2025/4 covering CommBank Yello income tax treatment. PR 2025/4 applies to benefits received up to 30 September 2026.

ATO Product Ruling PR 2026/18 confirms CommBank Yello loyalty benefits received by individual Australian residents are not taxable income.

ATO Tax Determination TD 2022/9 rules that US GILTI and NCTI income does not qualify as foreign income tax under Australia's hybrid mismatch rules in Division 8

The ATO has issued Addendum TD 2022/9A1 updating its ruling on US GILTI and Australian hybrid mismatch rules, applying from 1 January 2026.

The ATO has updated TR 2013/1 to reflect two court decisions changing how employment relationships are determined for tax treaty short-term visit exceptions.

ATO CR 2026/67 covers the tax treatment for Australian Strategic Materials shareholders whose shares were acquired by an Energy Fuels subsidiary on 28 August 20

The ATO has issued a minor erratum to Class Ruling CR 2013/14, replacing 'dentist' with 'dental practitioner' in paragraph 78. No GST treatment changes.

ATO Class Ruling CR 2026/66 confirms the BRE demerger CGT rules, cost base split and rollover options for shareholders who received Alurion Resources shares.