Product rulings: Product rulings 2006
Download product rulings for 2006
We issue product rulings only if both the following conditions are met:
- it is not feasible to seek a private ruling on the arrangement (this is generally because the identities of the other parties may not be known); and
- the characteristics of the taxpayers who may enter into the arrangement do not affect the content of the ruling.
Product rulings are issued by the Office of the Chief Tax Counsel (OCTC) business group of Inland Revenue. If you have any inquiries about product rulings:
- see A guide to binding rulings (IR715)
- contact us
The table below lists product rulings issued by year and number (BR Prd), with a brief description of the subject matter (earlier years will progressively be added) .
Caution should be exercised when looking at these product rulings:
- product rulings apply only to the arrangement specified in the ruling; a general similarity to an arrangement will not necessarily lead to the same tax result
- rulings generally expire after 3 years
- the table below does not indicate whether a ruling has expired (the expiry date of a ruling is set out in the text under the heading "The period for which this Ruling applies")
- occasionally, a ruling is withdrawn for one reason or another before its expiry date; the table below indicates that a ruling has been withdrawn only if the ruling would presently be current had it not been withdrawn.
Demerger of the Australian business of the TOWER group
Applicant: TOWER Consolidated Group
Under this ruling, the pro rata share cancellation by TOWER Ltd, where TOWER Australia Group Ltd shares are distributed to shareholders, does not constitute a "dividend", and the cancellation is not in lieu of the payment of a dividend.
Ruling applies from: 20 November 2006 to 31 March 2007
BR Prd 06/04 - RTF format (80kb | 3 pages)
BR Prd 06/04 - PDF format (36kb | 3 pages)
Provision of childcare services to employees
Applicant: Westpac Banking Corporation
Under this ruling, the amount of the reduction in salary agreed to by the employees pursuant to the salary reduction agreement, the childcare services supplied, and the payments under the management agreement, are not income of those employees, not "salary or wages", "extra pay" or a "withholding payment", and not "source deduction payments".
Ruling applies from: 7 July 2006 to 6 July 2009
BR Prd 06/03 - RTF format (121kb | 9 pages)
BR Prd 06/03 - PDF format (48kb | 9 pages)
Junk mail supervisors - whether employees or contractors
Applicant: LetterBox Channel Ltd
Under this ruling, supervisors of deliverers of newspapers, leaflets and advertising material are contractors, not employees, and therefore any payments made to them are not salary or wages.
Ruling applies from: 1 January 2006 to 31 December 2011
BR Prd 06/02 - RTF format (239kb | 13 pages)
BR Prd 06/02 - PDF format (125kb | 13 pages)
Junk mail deliverers - whether employees or contractors
Applicant: LetterBox Channel Ltd
Under this ruling, deliverers of newspapers, leaflets and advertising material are contractors, not employees, and therefore any payments made to them are not salary or wages.
Ruling applies from: 1 January 2006 to 31 December 2011
BR Prd 06/01 - RTF format (772kb | 13 pages)
BR Prd 06/01 - PDF format (237kb | 14 pages)
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Date published: 15 Jun 2007
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