NOTICE OF RULINGS

Ruling Number

Subject

Brief Description

CR 2015/22

Income tax:  Australia and New Zealand Banking Group Limited – ANZ Capital Notes 3

The Class Ruling sets out the Commissioner’s position for investors who are allotted non‑cumulative, convertible, transferable, redeemable, subordinated, perpetual, unsecured notes issued by Australia and New Zealand Banking Group Limited (ANZ) acting through its New Zealand branch, called ANZ Capital Notes 3.

The Ruling applies from 1 July 2014 to 30 June 2025.

TD 2015/2

Income tax:  will paragraph 974-80(1)(d) of the Income Tax Assessment Act 1997 be satisfied merely because a non-resident entity has chosen to invest indirectly in a debt interest issued by an Australian resident company and there is one or more equity interests interposed between the non-resident entity and the entity holding the debt interest?

The Determination sets out the Commissioner’s position on non-resident entity investment.

The Determination applies to years of income commencing both before and after its date of issue.

TD 2015/3

Income tax:  is the reference to ‘the interest’ as it appears in the phrase at the end of subsection 974‑80(2) of the Income Tax Assessment Act 1997 a reference to the interest held by the ‘ultimate recipient’?

The Determination sets out the Commissioner’s position on the reference to ‘the interest’ held by a recipient.

The Determination applies to years of income commencing both before and after its date of issue.