Class and Product Rulings issued – CR 2021/79-82, PR 2021/15

December 2, 2021
Four Class Rulings were issued on Wednesday 24 November 2021:
  • CR 2021/79 – Woolworths Group Limited – off-market share buy-back.
  • CR 2021/80 – Two10degrees Pty Ltd – use of Global Alerting Platform In Vehicle Management System for fuel tax credits.
  • CR 2021/81– Liontown Resources Limited – demerger of Minerals 260 Limited. The ATO accepts that a Div 125 demerger happened to the Liontown Resources demerger group. Accordingly, shareholders can choose to obtain demerger roll-over and are entitled to a dividend exemption.
  • CR 2021/82 Youfoodz Holdings Limited – employee share scheme – shares disposed of under scheme of arrangement. The ATO will allow the minimum holding period to end at an earlier time (27 October 2021) for the shares disposed of under the scheme.
The ATO also released Product Ruling PR 2021/15 on the tax consequences for a customer entering into a Prepay Plus Agreement with Nutrien Ag Solutions Limited. The ATO accepts that the prepayment amount is immediately deductible in the income year it is paid.