A public ruling, when issued, is the published view of the Commissioner of State Revenue (the Commissioner) on the particular topic to which it relates. It therefore replaces and overrides any existing private rulings, memoranda, manuals and advice provided by the Commissioner in respect of the issue(s) it addresses.
Where a change in legislation or case law (the law) affects the content of a public ruling, the change in the law overrides the public ruling—that is, the Commissioner will determine the tax liability or eligibility for a concession, grant or exemption, as the case may be, in accordance with the law.
A stapled security, comprising a share in X Ltd and a unit in Y Unit Trust, is quoted on the Australian Securities Exchange.
For the purposes of the Duties Act, each individual component of the stapled security—that is, the share in X Ltd and the unit in Y Unit Trust—is quoted in its own right on the Australian Securities Exchange.
For transactions involving the quoted stapled securities:
Commissioner of State Revenue
Date of issue: 3 September 2013
|Public Ruling||Issued||Dates of effect|
|DA000.5.4||3 September 2013||3 September 2013||Current|
|DA000.5.3||30 June 2011||1 July 2011||2 September 2013|
|DA000.5.2||15 April 2010||15 April 2010||30 June 2011|
|DA000.5.1||24 February 2009||24 February 2009||14 April 2010|
|Supersedes Practice Direction DA 78.3||10 October 2008||10 October 2008||23 February 2009|