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Notice of Rulings 31 January 2024

The Commissioner of Taxation, Chris Jordan, gives notice by notifiable instrument under subsection 358-5(4) of Schedule 1 to the Taxation Administration Act 1953 of the following public rulings, copies of which can be obtained from ato.gov.au/law

TR 2024/1

Income tax:  composite items – identifying the relevant depreciating asset for capital allowances

This Ruling addresses the issue of whether an asset that is made up of a number of parts or components (the composite item) is itself a depreciating asset, or whether one or more of its components are separate depreciating assets.

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

CR 2024/4

Allkem Limited – scrip for scrip roll‑over

This Ruling sets out the income tax consequences for the holders of ordinary shares in Allkem Limited who disposed of those shares to Arcadium Lithium plc on 4 January 2024.

The Ruling applies from 1 July 2023 to 30 June 2024.

CR 2024/5

Shriro Holdings Limited – return of capital

This Ruling sets out the income tax consequences for shareholders of Shriro Holdings Limited who received a return of share capital on 4 January 2024.

The Ruling applies from 1 July 2023 to 30 June 2024.

CR 2024/6

Healthia Limited – scheme of arrangement

This Ruling sets out the income tax consequences for Healthia Limited shareholders who exchanged their Healthia shares on 11 December 2023 for Class B shares in Harold Topco Ltd, by way of a scheme of arrangement.

The Ruling applies from 1 July 2023 to 30 June 2024.