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The dataset generation failed because of a cast error
Error code:   DatasetGenerationCastError
Exception:    DatasetGenerationCastError
Message:      An error occurred while generating the dataset

All the data files must have the same columns, but at some point there are 8 new columns ({'Relevant_Legislative_Provisions', 'Relevant_Facts_and_Circumstances', 'Date_of_Advice', 'Ruling_Period', 'Authorisation_Number', 'Date_Scheme_Commenced', 'Subject', 'Ruling'}) and 13 missing columns ({'Year_of_Income', 'Subject_References', 'Date_of_Decision', 'Related_Public_Rulings_and_Determinations', 'Issue', 'ATO_ID_Number', 'Facts', 'Related_ATO_Interpretative_Decisions', 'Status', 'Decision', 'Business_Line', 'Title', 'Legislative_References'}).

This happened while the csv dataset builder was generating data using

hf://datasets/simplelex/Aussie-Tax-Legal-Database/edited_private_advice_all.csv (at revision 60f79040c9ad220e5dad6096c9e6bc4685b0e368), [/tmp/hf-datasets-cache/medium/datasets/75393204626949-config-parquet-and-info-simplelex-Aussie-Tax-Lega-fdae29cf/hub/datasets--simplelex--Aussie-Tax-Legal-Database/snapshots/60f79040c9ad220e5dad6096c9e6bc4685b0e368/ato_interpretative_decisions.csv (origin=hf://datasets/simplelex/Aussie-Tax-Legal-Database@60f79040c9ad220e5dad6096c9e6bc4685b0e368/ato_interpretative_decisions.csv), /tmp/hf-datasets-cache/medium/datasets/75393204626949-config-parquet-and-info-simplelex-Aussie-Tax-Lega-fdae29cf/hub/datasets--simplelex--Aussie-Tax-Legal-Database/snapshots/60f79040c9ad220e5dad6096c9e6bc4685b0e368/edited_private_advice_all.csv (origin=hf://datasets/simplelex/Aussie-Tax-Legal-Database@60f79040c9ad220e5dad6096c9e6bc4685b0e368/edited_private_advice_all.csv), /tmp/hf-datasets-cache/medium/datasets/75393204626949-config-parquet-and-info-simplelex-Aussie-Tax-Lega-fdae29cf/hub/datasets--simplelex--Aussie-Tax-Legal-Database/snapshots/60f79040c9ad220e5dad6096c9e6bc4685b0e368/practical_compliance_guidelines.csv (origin=hf://datasets/simplelex/Aussie-Tax-Legal-Database@60f79040c9ad220e5dad6096c9e6bc4685b0e368/practical_compliance_guidelines.csv), /tmp/hf-datasets-cache/medium/datasets/75393204626949-config-parquet-and-info-simplelex-Aussie-Tax-Lega-fdae29cf/hub/datasets--simplelex--Aussie-Tax-Legal-Database/snapshots/60f79040c9ad220e5dad6096c9e6bc4685b0e368/public_all.csv (origin=hf://datasets/simplelex/Aussie-Tax-Legal-Database@60f79040c9ad220e5dad6096c9e6bc4685b0e368/public_all.csv)]

Please either edit the data files to have matching columns, or separate them into different configurations (see docs at https://hf.co/docs/hub/datasets-manual-configuration#multiple-configurations)
Traceback:    Traceback (most recent call last):
                File "/usr/local/lib/python3.12/site-packages/datasets/builder.py", line 1800, in _prepare_split_single
                  writer.write_table(table)
                File "/usr/local/lib/python3.12/site-packages/datasets/arrow_writer.py", line 765, in write_table
                  self._write_table(pa_table, writer_batch_size=writer_batch_size)
                File "/usr/local/lib/python3.12/site-packages/datasets/arrow_writer.py", line 773, in _write_table
                  pa_table = table_cast(pa_table, self._schema)
                             ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
                File "/usr/local/lib/python3.12/site-packages/datasets/table.py", line 2321, in table_cast
                  return cast_table_to_schema(table, schema)
                         ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
                File "/usr/local/lib/python3.12/site-packages/datasets/table.py", line 2249, in cast_table_to_schema
                  raise CastError(
              datasets.table.CastError: Couldn't cast
              Authorisation_Number: int64
              Date_of_Advice: string
              Subject: string
              Ruling: string
              Ruling_Period: string
              Date_Scheme_Commenced: string
              Relevant_Facts_and_Circumstances: string
              Relevant_Legislative_Provisions: string
              Reasons_for_Decision: string
              Is_Archived: bool
              Source_URL: string
              -- schema metadata --
              pandas: '{"index_columns": [{"kind": "range", "name": null, "start": 0, "' + 1725
              to
              {'ATO_ID_Number': Value('string'), 'Status': Value('string'), 'Title': Value('string'), 'Issue': Value('string'), 'Decision': Value('string'), 'Facts': Value('string'), 'Reasons_for_Decision': Value('string'), 'Date_of_Decision': Value('float64'), 'Year_of_Income': Value('string'), 'Legislative_References': Value('string'), 'Related_Public_Rulings_and_Determinations': Value('string'), 'Related_ATO_Interpretative_Decisions': Value('float64'), 'Subject_References': Value('float64'), 'Business_Line': Value('float64'), 'Is_Archived': Value('bool'), 'Source_URL': Value('string')}
              because column names don't match
              
              During handling of the above exception, another exception occurred:
              
              Traceback (most recent call last):
                File "/src/services/worker/src/worker/job_runners/config/parquet_and_info.py", line 1347, in compute_config_parquet_and_info_response
                  parquet_operations = convert_to_parquet(builder)
                                       ^^^^^^^^^^^^^^^^^^^^^^^^^^^
                File "/src/services/worker/src/worker/job_runners/config/parquet_and_info.py", line 980, in convert_to_parquet
                  builder.download_and_prepare(
                File "/usr/local/lib/python3.12/site-packages/datasets/builder.py", line 882, in download_and_prepare
                  self._download_and_prepare(
                File "/usr/local/lib/python3.12/site-packages/datasets/builder.py", line 943, in _download_and_prepare
                  self._prepare_split(split_generator, **prepare_split_kwargs)
                File "/usr/local/lib/python3.12/site-packages/datasets/builder.py", line 1646, in _prepare_split
                  for job_id, done, content in self._prepare_split_single(
                                               ^^^^^^^^^^^^^^^^^^^^^^^^^^^
                File "/usr/local/lib/python3.12/site-packages/datasets/builder.py", line 1802, in _prepare_split_single
                  raise DatasetGenerationCastError.from_cast_error(
              datasets.exceptions.DatasetGenerationCastError: An error occurred while generating the dataset
              
              All the data files must have the same columns, but at some point there are 8 new columns ({'Relevant_Legislative_Provisions', 'Relevant_Facts_and_Circumstances', 'Date_of_Advice', 'Ruling_Period', 'Authorisation_Number', 'Date_Scheme_Commenced', 'Subject', 'Ruling'}) and 13 missing columns ({'Year_of_Income', 'Subject_References', 'Date_of_Decision', 'Related_Public_Rulings_and_Determinations', 'Issue', 'ATO_ID_Number', 'Facts', 'Related_ATO_Interpretative_Decisions', 'Status', 'Decision', 'Business_Line', 'Title', 'Legislative_References'}).
              
              This happened while the csv dataset builder was generating data using
              
              hf://datasets/simplelex/Aussie-Tax-Legal-Database/edited_private_advice_all.csv (at revision 60f79040c9ad220e5dad6096c9e6bc4685b0e368), [/tmp/hf-datasets-cache/medium/datasets/75393204626949-config-parquet-and-info-simplelex-Aussie-Tax-Lega-fdae29cf/hub/datasets--simplelex--Aussie-Tax-Legal-Database/snapshots/60f79040c9ad220e5dad6096c9e6bc4685b0e368/ato_interpretative_decisions.csv (origin=hf://datasets/simplelex/Aussie-Tax-Legal-Database@60f79040c9ad220e5dad6096c9e6bc4685b0e368/ato_interpretative_decisions.csv), /tmp/hf-datasets-cache/medium/datasets/75393204626949-config-parquet-and-info-simplelex-Aussie-Tax-Lega-fdae29cf/hub/datasets--simplelex--Aussie-Tax-Legal-Database/snapshots/60f79040c9ad220e5dad6096c9e6bc4685b0e368/edited_private_advice_all.csv (origin=hf://datasets/simplelex/Aussie-Tax-Legal-Database@60f79040c9ad220e5dad6096c9e6bc4685b0e368/edited_private_advice_all.csv), /tmp/hf-datasets-cache/medium/datasets/75393204626949-config-parquet-and-info-simplelex-Aussie-Tax-Lega-fdae29cf/hub/datasets--simplelex--Aussie-Tax-Legal-Database/snapshots/60f79040c9ad220e5dad6096c9e6bc4685b0e368/practical_compliance_guidelines.csv (origin=hf://datasets/simplelex/Aussie-Tax-Legal-Database@60f79040c9ad220e5dad6096c9e6bc4685b0e368/practical_compliance_guidelines.csv), /tmp/hf-datasets-cache/medium/datasets/75393204626949-config-parquet-and-info-simplelex-Aussie-Tax-Lega-fdae29cf/hub/datasets--simplelex--Aussie-Tax-Legal-Database/snapshots/60f79040c9ad220e5dad6096c9e6bc4685b0e368/public_all.csv (origin=hf://datasets/simplelex/Aussie-Tax-Legal-Database@60f79040c9ad220e5dad6096c9e6bc4685b0e368/public_all.csv)]
              
              Please either edit the data files to have matching columns, or separate them into different configurations (see docs at https://hf.co/docs/hub/datasets-manual-configuration#multiple-configurations)

Need help to make the dataset viewer work? Make sure to review how to configure the dataset viewer, and open a discussion for direct support.

ATO_ID_Number
string
Status
string
Title
string
Issue
string
Decision
string
Facts
string
Reasons_for_Decision
string
Date_of_Decision
null
Year_of_Income
string
Legislative_References
string
Related_Public_Rulings_and_Determinations
string
Related_ATO_Interpretative_Decisions
null
Subject_References
null
Business_Line
null
Is_Archived
bool
Source_URL
string
ATO ID 2010/115
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Mining withholding tax: withholding from mining payment - GST inclusive basis
Is an entity required to calculate the amount to be withheld from the payment on a goods and services tax (GST) inclusive basis where the entity is required to withhold an amount from a mining payment in accordance with section 12-320 of Schedule 1 to the Taxation Administration Act 1953 (TAA), and the payment is given...
Yes. The amount to be withheld from the mining payment in accordance with section 12-320 of Schedule 1 to the TAA should be calculated on a GST inclusive basis.
A mining company made payments to an Aboriginal Land Council (ALC) under an agreement in relation to the use of the aboriginal land for mining and exploration. The payments under the agreement are mining payments within the meaning of the term in paragraph 128U(1)(b) of the Income Tax Assessment Act 1936 (ITAA 1936). T...
Summary: An entity is required to withhold an amount from a mining payment that it makes to another entity: subsection 12-320(1) of Schedule 1 to the TAA. The amount to be withheld from the mining payment is 4% of the amount of the payment: see regulation 43 of the Taxation Administration Regulations 1976. The amount w...
null
Year ended 2009-10 and later income years
Aboriginal Land Rights (Northern Territory) Act 1976 section 21
(including Determinations) Taxation Ruling TR 2002/9 Taxation Ruling TR 2006/12
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2010115
ATO ID 2003/872
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Reconsideration of a reviewable decision
Can the Regulator make a decision with respect to a 'reviewable decision' under section 344 of the Superannuation Industry (Supervision) Act 1993 (SISA) once the sixty-day period allowed to review the decision by subsection 344(5) of the SISA has lapsed?
No, the Regulator cannot make a decision with respect to a 'reviewable decision' under section 344 of the SISA once the sixty day period allowed to review the decision by subsection 344(5) of the SISA has lapsed.
The trustee requested that the Regulator reconsider a reviewable decision pursuant to subsection 344(1) of the SISA. The Regulator did not respond to the request for a review within the sixty-day period allowed by subsection 344(5) of the SISA.
Summary: Subsection 344(1) of the SISA allows a person who is dissatisfied with a decision of the Regulator to request a review of the decision. Subsection 344(1) of the SISA states: 'A person who is affected by a reviewable decision of the Regulator may, if dissatisfied with the decision, request the Regulator to reco...
null
Year ended 30 June 2003
Superannuation Industry (Supervision) Act 1993 Subsection 10(1) Section 344 Subsection 344(1) Subsection 344(5)
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2003872
ATO ID 2011/86
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
PAYG Withholding: penalty for failure to withhold - liability to general interest charge
Does the date for calculating an entity's liability for general interest charge (GIC) in relation to a failure to withhold penalty imposed prior to 22 June 2006 commence from the time set under former subsection 16-30(2) of Schedule 1 to the Taxation Administration Act 1953 (TAA)?
Yes. The entity's liability to GIC commences from the time set by former subsection 16-30(2) of Schedule 1 to the TAA, as this provision has continuing effect for penalties imposed prior to 22 June 2006.
An entity made a payment to a non-resident company after 1 July 2000 but before 22 June 2006. The payment was in the nature of a royalty and was subject to pay as you go withholding under section 12-280 of Schedule 1 to the TAA. The payer did not withhold an amount from the royalty it paid to the non-resident company. ...
Summary: Under former subsection 16-30(1) of Schedule 1 to the TAA, an entity that failed to withhold an amount as required by Division 12 of Schedule 1 to the TAA is liable to pay to the Commissioner a penalty equal to that amount. Under former subsection 16-30(2) of Schedule 1 to the TAA the penalty amount was due at...
null
Year ended 30 June 2011
Tax Laws Amendment (2006 Measures No.2) Act 2006 The Act
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID201186
ATO ID 2006/176
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
GST and GST returns where company ownership changes from 1 July 2006
Is the entity, a company, required to submit a GST return under subsection 31-5(1) of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act), when the ownership of the entity changes before the end of the tax period?
No, the entity is not required to submit a GST return under subsection 31-5(1) of the GST Act when the ownership of the entity changes before the end of the tax period. The entity is required to submit one GST return at the end of the tax period covering the whole of the tax period.
The entity is a company that is registered under the Corporations Act 2001 . It is registered for goods and services tax (GST) and lodges its GST returns quarterly. The ownership of the company changed part way through a tax period.
Summary: Subsection 31-5(1) of the GST Act provides that an entity that is registered or required to be registered, must give to the Commissioner a GST return for each tax period. For GST purposes, subsection 184-1(1) of the GST Act defines 'entity' to include a body corporate and other unincorporated association or bo...
null
null
A New Tax System (Goods and Services Tax) Act 1999 section 27-5 subsection 31-5(1) subsection 184-1 section 195-1
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2006176
ATO ID 2003/506
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Taxation obligations of company administrators
Does section 254 of the Income Tax Assessment Act 1936 (ITAA 1936) apply to make an administrator appointed under Part 5.3A of the Corporations Act 2001 (Corporations Act), personally liable for income tax assessed to the company in relation to which they are appointed?
Yes. An administrator is a trustee of the company for the purposes of section 254 of the ITAA 1936. An administrator is personally liable under paragraph 254(1)(e) for the tax payable in respect of income, or profits or gains of a capital nature derived by virtue of that representative capacity. However, the administra...
An administrator is appointed under the Corporations Act Part 5.3A and income is derived during the company's administration.
Summary: Section 254 of the ITAA 1936 applies to an entity that is an agent or trustee for the purposes of the ITAA 1936 and 1997. Section 254 contains provisions which describe the duties and obligations of persons who act as the agents or trustees of taxpayers. 'Trustee' is defined in subsection 6(1) of the ITAA 1936...
null
Year ended 30 June 2003
Income Tax Assessment Act 1936 subsection 6(1) section 254 subsection 254(1) paragraph 254(1)(b) paragraph 254(1)(d) paragraph 254(1)(e) section 221P
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2003506
ATO ID 2013/45
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Shipping activities income: exclusion from instalment income
Can ordinary income derived by a taxpayer be excluded from instalment income for the purposes of section 45-120 of Schedule 1 to the Taxation Administration Act 1953 (TAA 1953) to the extent that it is from shipping activities that relate to a vessel in respect of which the taxpayer expects to be issued with a shipping...
Yes, ordinary income derived by a taxpayer can be excluded from instalment income for the purposes of section 45-120 of Schedule 1 to the TAA 1953 to the extent that it is from shipping activities that relate to a vessel in respect of which the taxpayer expects to be issued with a shipping exempt income certificate und...
The taxpayer is a corporation which derives ordinary income during an income year (relevant income year) from shipping activities that relate to a vessel. The vessel meets the requirements of section 10 of the SRTIA 2012. The taxpayer has been given an instalment rate by the Commissioner through a written notice under ...
Summary: Section 45-15 of Schedule 1 to the TAA 1953 establishes a general liability to pay instalments if the Commissioner issues an instalment rate to a taxpayer. Subsection 45-50(1) of Schedule 1 to the TAA 1953 establishes a specific liability to pay an instalment for an instalment quarter in an income year if at t...
null
Year ended 30 June 2013
Income Tax Assessment Act 1997 subsection 51-100(1)
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID201345
ATO ID 2006/295
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
PAYG instalment rate: varying the rate upwards and the general interest charge
Will the company be liable for the general interest charge (GIC) under section 45-230 of Schedule 1 to the Taxation Administration Act 1953 (TAA) if it varies its pay as you go (PAYG) instalment rate upwards and it is less than 85% of its benchmark instalment rate for the income year?
Yes. The company will be liable for the GIC under section 45-230 of Schedule 1 to the TAA if it varies its PAYG instalment rate upwards and it is less than 85% of its benchmark instalment rate for the income year. However, in the circumstances it is appropriate for the Commissioner to exercise his discretion to remit t...
The company was notified by the Commissioner on 28 April 2006 that its PAYG instalment rate with effect from 1 April 2006 was 0%. Previously, the company was notified by Commissioner on 28 April 2005 that its PAYG instalment rate with effect from 1 April 2005 was also 0%. On 28 April 2006, the company varied its PAYG i...
Summary: Under subsection 45-230(1) of Schedule 1 to the TAA, an entity is liable to pay the GIC if: The company has varied its instalment rate upwards. However its varied rate is expected to be less than 85% of its benchmark instalment rate. GIC is payable on the amount worked out using the formula in subsection 45-23...
null
Year ended 30 June 2006
Taxation Administration Act 1953 section 3AA subsection 3AA(3) section 45-205 Subdivision 45-G subsection 45-230(1) subsection 45-230(2) section 45-240 Subdivision 45-K
null
null
null
null
true
https://www.ato.gov.au/law/view/document?docid=AID/AID2006295
ATO ID 2005/237
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
PAYG Instalment Income and Employee Share Scheme
Is the discount that a taxpayer receives, as an employee, on a qualifying right that the taxpayer acquires under an employee share acquisition scheme included in the taxpayer's PAYG instalment income if the taxpayer does not make an election under subsection 139E(1) of the Income Tax Assessment Act 1936 (ITAA 1936)?
No, the discount that the taxpayer, an employee receives, on a qualifying right that the taxpayer acquires under an employee acquisition share scheme is not included in the taxpayer's PAYG instalment income if the taxpayer does not make an election under subsection 139E(1) of the ITAA 1936.
The taxpayer is an employee who is granted rights to acquire shares at a discount under an employee share acquisition scheme. The right has an expiration date of a number of years from the date of granting the right. The rights are qualifying rights for the purposes of Division 13A of the ITAA 1936. The taxpayer has no...
Summary: Section 45-120 of Schedule 1 to the Taxation Administration Act 1953 (TAA) provides that instalment income for a period includes ordinary income derived during that period, but only to the extent that it is assessable income of the income year that is or includes that period. Under subsection 139B(1) of the IT...
null
Year ended 30 June 2005 Year ended 30 June 2006 Year ended 30 June 2007 Year ended 30 June 2008
Income Tax Assessment Act 1936 section 139B section 139E
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2005237
ATO ID 2004/798
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Income Tax: change from a co-operative to a company
Is the taxpayer the same 'entity' for all purposes under the Income Tax Assessment Act 1997 (ITAA 1997) after the conversion from an incorporated co-operative to a company?
Yes. The taxpayer's registration as a company under the Corporations Act 2001 (Cth) (Corporations Act) does not create a new legal entity. Therefore it is the same 'entity' for all purposes of the ITAA 1997 as defined in section 960-100 of the ITAA 1997.
The taxpayer is a co-operative incorporated under the Co-operatives Act 1992 (NSW) (Co-op Act). The taxpayer is treated as a body corporate pursuant to its incorporation under the Co-op Act. The taxpayer will transfer its incorporation under the Co-op Act to become a company registered under the Corporations Act. It wi...
Summary: The co-operative incorporated under the Co-op Act is a body corporate under that Act and at general law. Section 995-1 of the ITAA 1997 defines an 'entity' to have the meaning in section 960-100 of the ITAA 1997. An 'entity' is defined to mean any of the following: In addition, section 995-1 of the ITAA 1997 d...
null
Year ended 30 June 2004
Income Tax Assessment Act 1997 section 995-1 section 960-100 paragraph 960-100(1)(b)
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2004798
ATO ID 2011/65
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
PAYG Withholding: penalty for failure to withhold - imposition of penalty
When is a penalty for failing to withhold imposed on an entity under section 16-30 of Schedule 1 to the Taxation Administration Act 1953 (TAA)?
The penalty under section 16-30 of Schedule 1 to the TAA is imposed at the time the entity failed to withhold from the payment.
After 1 July 2000 an entity makes a payment to another entity from which an amount was required to be withheld under Division 12 of Schedule 1 to the TAA. The ATO commenced an audit of the payer's affairs. The Commissioner identified that the payer had failed to withhold from the payment and notified the payer of the l...
Summary: With effect from 1 July 2000, an entity that fails to withhold an amount as required by Division 12 of Schedule 1 to the TAA is liable to pay to the Commissioner a penalty equal to that amount under section 16-30 of Schedule 1 to the TAA. The current section 16-30 was inserted by Tax Laws Amendment (2006 Measu...
null
Year ended 30 June 2011
Administrative Decisions (Judicial Review) Act 1977 The Act
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID201165
ATO ID 2007/187
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Failure to withhold from an interest payment to a non-resident and the effect on the payment's deductibility
Does the payment of an administrative penalty amount imposed under section 16-30 of Schedule 1 to the Taxation Administration Act 1953 (TAA), for failure to withhold from interest paid to a non-resident, constitute a payment of withholding tax for the purposes of subsection 26-25(3) of the Income Tax Assessment Act 199...
Yes. The payment of an administrative penalty amount imposed under section 16-30 of Schedule 1 to the TAA, for failure to withhold from interest paid to a non-resident, constitutes a payment of withholding tax for the purposes of subsection 26-25(3) of the ITAA 1997.
An Australian resident entity (the payer) made a payment of interest to an overseas person who is a non-resident. An overseas person, for the purposes of section 12-245 of Subdivision 12-F of Schedule 1 to the TAA, is the recipient of the interest who, from the payer's records has an address outside of Australia. The i...
Summary: Subsection 128B(5) of the ITAA 1936 imposes a withholding tax liability on a non-resident who derives interest which is paid by a person who is a resident (subparagraph 128B(2)(b)(i) of the ITAA 1936) or by a non-resident who incurs the interest in carrying on business in Australia at or through a permanent es...
null
not applicable
Income Tax Assessment Act 1936 section 128B subparagraph 128B(2)(b)(i) subparagraph 128B(2)(b)(ii) subsection 128B(5)
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2007187
ATO ID 2012/3
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Amendment of Assessments: time limits for amending assessments for an individual and the application of Regulation 20 of the Income Tax Regulations 1936
When the Commissioner exercises his discretion under subsection 109RB(2) of the Income Tax Assessment Act 1936 (ITAA 1936), does item 2 of regulation 20 of Income Tax Regulations 1936 (Regulation 20) apply to increase the standard amendment period from two to four years because of the qualification in paragraph (f) of ...
No. The standard two year amendment period will still apply as the Commissioner has exercised his discretion under subsection 109RB(2) of the ITAA 1936. The qualification in paragraph (f) of the table in subsection 170(1) of the ITAA 1936 does not apply because the circumstance prescribed by item 2 in the table of Regu...
A taxpayer is an individual shareholder in a private company which made a loan to a controlled trust during the relevant income year. The loan comes within section 109D of the ITAA 1936, being a loan that is treated as a dividend in the year it was made. However, the Commissioner can exercise his discretion in section ...
Summary: The two year amendment period in item 1 of the table in subsection 170(1) of the ITAA 1936 is subject to certain exceptions or 'qualifications' in that item. One such qualification is paragraph (f) which provides that the two year amendment period does not apply 'in any other circumstance prescribed by the reg...
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Year ended 30 June 2012
Income Tax Assessment Act 1936 subsection 170(1) Division 7A section 109C section 109D section 109F section 109RB subsection 109RB(2) subsection 109RB(5)
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID20123
ATO ID 2012/51
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Assessments for the 2003-04 and earlier nil years: nil liability return for the 2003-04 income year: limited period for making an original assessment for a nil year: taxpayer consented to extending the limited amendment periods for the 2003-04 and later relevant income years
Can the Commissioner make an original assessment for the 2003-04 income year after the limited period specified in item 1 in the table in subsection 171A(1) of the Income Tax Assessment Act 1936 (ITAA 1936) has expired where the taxpayer has:
No. The Commissioner is unable to make an original assessment for the 2003-04 income year as the limited period set out in item 1 in the table in subsection 171A(1) of the ITAA 1936 has expired. The taxpayer's consent under former subsection 170(4) of the ITAA 1936 is irrelevant.
An individual lodged a nil return for the 2003-04 income year on 1 December 2006. It was a nil return because it showed that the taxpayer had no taxable income as the taxpayer's deductions equalled the taxpayer's assessable income. The taxpayer did not deduct a tax loss in the 2003-04 income year. The Commissioner comm...
Detailed Reasoning - Limited period for making an original assessment for the 2003-04 nil year: Section 171A of the ITAA 1936 sets out the limited periods in which the Commissioner may make original assessments for nil returns for the 2003-04 income year and earlier income years, referred to in that section as nil year...
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Year ended 30 June 2004
Income Tax Assessment Act 1936 former subsection 170(4) former subsection 170(1A) subsection 170(7) section 171A subsection 171A(1)
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID201251
ATO ID 2011/102
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Amendment of income tax assessment outside limited amendment period on an application for amendment by the taxpayer
Does the Commissioner have the power to amend an income tax assessment for an income year under subsection 170(5) of the Income Tax Assessment Act 1936 (ITAA 1936) to include additional income where:
No. The Commissioner is outside the 2 year limited amendment period under subsection 170(1) of the ITAA 1936 and cannot amend the assessment under subsection 170(5) of the ITAA 1936 to include the additional income in the taxpayer's assessment. The Commissioner can only amend the assessment in relation to the additiona...
A taxpayer (an individual) is a partner in a partnership. The partnership requested an amendment of the partnership income tax return for an income year (the relevant year) on the basis of a claim for additional partnership deductions. The taxpayer lodged an application for amendment of their income tax assessment for ...
Summary: Under item 1 of the table in subsection 170(1) of the ITAA 1936, the Commissioner may amend the taxpayer's assessment within the limited amendment period to either increase or decrease the taxpayer's liability. Because of legislative amendments to section 170 of the ITAA 1936 enacted by Parliament in 2005, the...
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Year ended 30 June 2012
Income Tax Assessment Act 1936 section 170 subsection 170(1) subsection 170(5) subsection 170(7)
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2011102
ATO ID 2010/42
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Amendment of assessments: exception to two year period of review if an individual is a beneficiary of trust estate
Does the two year time limit in item 1 in the table in subsection 170(1) of the Income Tax Assessment Act 1936 (ITAA 1936) apply to prevent the Commissioner from amending an individual's assessment where:
No. The two year time limit in item 1 in the table in subsection 170(1) of the ITAA 1936 does not apply in this case because one of the exceptions in paragraph (d) applies.
A resident individual was a beneficiary of a resident family discretionary trust. The trustee of the trust was a private company. The trust was not a small business entity within the meaning of the term in subsection 995-1(1) of the Income Tax Assessment Act 1997 (ITAA 1997). The Commissioner gave the individual a noti...
Summary: The general rule is that the Commissioner may amend an assessment of an individual for a year of income within two years after the day on which the Commissioner gives notice of the assessment to the individual (two year period to amend): item 1 in the table in subsection 170(1) of the ITAA 1936. However, there...
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Year ended 2004-05 and later income years
Income Tax Assessment Act 1936 subsection 6(1) section 166 subsection 166A(3) section 169 subsection 170(1)
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null
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null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID201042
ATO ID 2010/226
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Amendment of assessments: time limits for amending assessments where Regulation 20 of the Income Tax Regulations 1936 applies and the matters for which assessments may be amended
Where the Commissioner determines that section 45B of the Income Tax Assessment Act 1936 (ITAA 1936) applies to a taxpayer and therefore, the taxpayer is subject to the four year amendment period as prescribed by Regulation 20 of the Income Tax Regulations 1936 (Regulation 20), is the Commissioner limited in his amendm...
No. Once the Commissioner determines that Regulation 20 applies to the taxpayer, the Commissioner is not limited to amending the taxpayer's assessment only in relation to section 45B of the ITAA 1936. The Commissioner may amend the taxpayer's assessment concerning any matter within the prescribed amendment period, bein...
As a result of a corporate restructure, shares were transferred to an individual taxpayer who was a shareholder of the corporate group in the 2005-06 income year. On the same day the taxpayer acquired their shares, they disposed of them. The taxpayer lodged their tax return for the 2005-06 income year in 2006 and was g...
Summary: The two year amendment period in item 1 in the table in subsection 170(1) of the ITAA 1936 is subject to the exceptions or 'qualifications' in that item. One such qualification is paragraph (f) which provides that the two year amendment period does not apply 'in any other circumstances prescribed by the regula...
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Year ended 30 June 2006
Income Tax Assessment Act 1936 section 45B paragraph 45B(3)(b) section 45C subsection 170(1)
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2010226
ATO ID 2012/57
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Assessments for the 2003-04 and earlier nil years: notifying the Commissioner in the approved form for the purposes of item 4 of the table in subsection 171A(1) of the Income Tax Assessment Act 1936
Does disclosure by a company of an amount of tax losses deducted at label R of item 7 of its company income tax return for the 2004-05 income year provide notification to the Commissioner, in the approved form, for the purposes of item 4 of the table in subsection 171A(1) of the Income Tax Assessment Act 1936 (ITAA 193...
Yes, where a company is not required to complete the Losses schedule 2005 and it discloses an amount of tax losses deducted at label R of item 7 of its company income tax return for the 2004-05 income year, it is at this point that the company notifies the Commissioner, in the approved form, that it had a tax loss in a...
Company X incurred a tax loss in the 2002-03 income year and consequently lodged a nil liability company income tax return for the 2002-03 income year in June 2004. Company X utilised a portion of this carried forward loss in the 2003-04 income year and carried forward the remainder to the 2004-05 income year where the...
Summary: Section 171A of the ITAA 1936 limits the period within which the Commissioner can make an original assessment for nil liability income tax returns for the 2003-04 and earlier income years. Essentially, an original assessment can only be made for these nil years within a limited period according to the circumst...
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Year ended 30 June 2003
Income Tax Assessment Act 1936 section 171A subsection 171A(1)
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID201257
ATO ID 2010/223
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Fuel tax credits: GST groups - applications for private rulings
Does section 70-5 of the Fuel Tax Act 2006 (FTA) prevent an entity that is a member of a GST group, but is not the representative member of the group, from applying for a private ruling in relation to transactions they enter into that affect the net fuel amount of the group?
Yes. Section 70-5 of the FTA prevents an entity that is a member of a GST group, but is not the representative member of that group, from applying for a private ruling in relation to transactions they enter into that affect the net fuel amount of the group because the right to seek the ruling has transferred to the rep...
An entity is a member of a GST group. The entity is not the representative member of the GST group. The entity enters into a transaction that affects the net fuel amount of the GST group.
Summary: Division 357 of Schedule 1 to the Taxation Administration Act 1953 (TAA) sets out common rules that apply to rulings. Under paragraph 357-55(i) of Schedule 1 of the TAA, a ruling can be made in relation to a net fuel amount, or the administration, collection or payment of a net fuel amount. Subsection 359-5(1)...
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null
Fuel Tax Act 2006 section 70-5 section 110-5
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null
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null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2010223
ATO ID 2003/78
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Group company net capital loss transfers: valid transfer agreement - single document with multiple agreements
Can a loss company validly transfer various amounts of net capital losses to two or more gain companies in a single document (the Document) for the purposes of section 170-150 of the Income Tax Assessment Act 1997 (ITAA 1997)?
Yes. As the Document satisfies the requirements of subsection 170-150(2) of the ITAA 1997, the fact that it incorporates several written agreements does not of itself invalidate those agreements.
The public officer of a loss company and the public officer of several gain companies in a wholly owned group agreed for the loss company to transfer various amounts of net capital loss incurred by the loss company to the several gain companies in respect of an income year that ended after 30 June 1998. Rather than pre...
Summary: Subsection 170-150(1) of the ITAA 1997 requires that a transfer of a net capital loss must be made by a written agreement. The ITAA 1997 does not prescribe that the written agreement must be in any particular form. However, subsection 170-150(2) of the ITAA 1997 states that the agreement must: As the Document ...
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Year ended 30 June 2002
Income Tax Assessment Act 1997 Subdivision 170-B section 170-150 subsection 170-150(1) subsection 170-150(2) paragraph 170-150(2)(d)
(including Determinations) Taxation Ruling TR 98/12
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null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID200378
ATO ID 2003/351
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Group company loss transfers: net capital loss incurred during part of capital loss year after loss company became a member of a wholly-owned group
Can a net capital loss, incurred by a loss company during the part of the capital loss year after it became a member of a wholly-owned group, be transferred to a gain company within the same group under Subdivision 170-B of the Income Tax Assessment Act 1997 (ITAA 1997)?
No. A net capital loss transfer is not permitted because the loss company was not a member of the same wholly-owned group as the gain company for the entire capital loss year, as required under subsection 170-130(2) of the ITAA 1997.
A company (the 'loss company') became a member of the same wholly-owned group as another company (the 'gain company') following the acquisition of the shares in the loss company by the holding company of the group during an income year (the 'capital loss year'). The loss company incurred a net capital loss during the p...
Summary: As a condition for transferring a net capital loss, subsection 170-130(2) of the ITAA 1997 requires that both the loss company and the gain company must be members of the same wholly-owned group at all times during the capital loss year, the application year and intervening years when both companies were in ex...
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Year ended 30 June 2003
Income Tax Assessment Act 1997 Subdivision 170-B subsection 170-130(2) subsection 975-100(1)
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2003351
ATO ID 2002/964
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital gains tax: trusts: calculation of beneficiary's net capital gain
Can a beneficiary reduce the share of a trust's net income that is included in their assessable income under section 97 of the Income Tax Assessment Act 1936 (ITAA 1936), by its prior year capital losses?
o. The beneficiary can only apply their capital losses against the extra capital gains that they are taken to have made under Subdivision 115-C of the Income Tax Assessment Act 1997 (ITAA 1997).
An Australian resident beneficiary, who is not under a legal disability, is presently entitled to a share of trust income in the 2002 income year. The beneficiary's share of the net income of the trust for the 2002 income year is attributable to a discount capital gain of $5 million. The beneficiary had a $15 million n...
Summary: A beneficiary who is not under a legal disability and who is presently entitled to a share of the income of a trust must include in their assessable income their share of the net income of the trust estate (section 97 of the ITAA 1936). Subdivision 115-C of the ITAA 1997 sets out rules that affect the calculat...
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Year ended 30 June 2002
Income Tax Assessment Act 1936 section 97
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2002964
ATO ID 2001/799
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital gains tax: capital losses: rights in relation to non-resident company
Has any CGT event in Division 104 of the Income Tax Assessment Act 1997 (ITAA 1997) happened to enable the taxpayer to make a capital loss in relation to their right to sue a Thai securities firm?
No. As no CGT event in Division 104 of the ITAA 1997 has happened to the right to sue the securities firm, the taxpayer is unable to claim a capital loss. If a CGT event occurs in relation to the taxpayer's rights in the future, the taxpayer may make a capital loss at that time.
The taxpayer received an offer to invest in a non-resident company through a securities firm based in Thailand. The taxpayer forwarded US dollars to the firm's bank accounts overseas. The taxpayer has not received share certificates for their investment. The Thai securities firm has been under investigation by authorit...
Summary: Section 102-20 of ITAA 1997 provides that you make a capital gain or capital loss if and only if a CGT event happens. The gain or loss is made at the time of the CGT event. If the taxpayer's investment has been embezzled the relevant CGT asset will be the right to sue the Thai securities firm to seek compensat...
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Year ended 30 June 2001
Income Tax Assessment Act 1997 section 102-20 section 104-25 subsection 104-25(1)
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null
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null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2001799
ATO ID 2010/121
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital gains tax: amalgamation of controlled foreign companies - cancellation of shares - capital proceeds for CGT event C2
What are the capital proceeds under Division 116 of the Income Tax Assessment Act 1997 ( ITAA 1997) from the cancellation of shares in a controlled foreign company as a result of the company amalgamating with another controlled foreign company in accordance with specific legislation in their jurisdiction of residence?
The capital proceeds are nil. Having regard to the legislation governing the amalgamation, no money or property is received, or entitled to be received, in respect of the cancellation of the shares for the purposes of section 116-20 of the ITAA 1997. While the market value substitution rule in subsection 116-30(1) of t...
A resident company wholly owns a non-resident subsidiary (Z Co). Z Co wholly owns another non-resident subsidiary (Y Co). Z Co and Y Co amalgamate in accordance with specific legislation in the jurisdiction in which they both reside. Z Co will continue as the amalgamated company. The relevant legislation provides that ...
Summary: Under subsection 116-20(1) of the ITAA 1997, the capital proceeds from a CGT event are the total of the money received (or entitled to be received) and the market value of property received (or entitled to be received) in respect of the event happening. As the relevant legislation prohibits Z Co from receiving...
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Year ended 30 June 2004
Income Tax Assessment Act 1997 section 104-25 Division 116 section 116-20 subsection 116-20(1) subsection 116-30(1) subsection 116-30(3A) Division 727
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null
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null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2010121
ATO ID 2003/517
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital gains: capital proceeds arising from the grant of a licence to use premises
Is a licencee's undertaking to pay ongoing licence fees for the use of facilities included in the licensor's capital proceeds for CGT event D1 (section 104-35 of the Income Tax Assessment Act 1997 (ITAA 1997))?
No. A licencee's undertaking to pay on-going licence fees is not included in capital proceeds for CGT event D1 (section 104-35 of the ITAA 1997) because the undertaking is not received by the licensor 'in respect of the event happening' for the purposes of paragraph 116-20(1)(b) of the ITAA 1997.
A Licence Agreement was entered into between Company A and Company B after 20 September 1985. Under the Licence Agreement, Company A was granted a non-exclusive right to use port facilities by Company B in consideration for a Licence Fee. The Licence Fee is to be paid over the term of the Licence from income generated ...
Summary: CGT event D1 happens if a taxpayer creates a contractual right or other legal or equitable right in another entity (subsection 104-35(1) of the ITAA 1997). In the present case, CGT event D1 happens when Company B enters into the Licence Agreement with Company A. Company B has created a right to use the port fa...
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Year ended 30 June 2003
Income Tax Assessment Act 1997 section 104-35 subsection 104-35(3) subsection 116-20(1) paragraph 116-20(1)(b)
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2003517
ATO ID 2003/636
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
CGT: Capital proceeds payable by instalments - not all received - no reduction of capital proceeds received
Where the 'consideration in respect of the disposal of an asset' is payable by instalments over time, is that consideration later reduced under former paragraph 160ZD(1)(a) of the Income Tax Assessment Act 1936 (ITAA 1936) if some of the monies are ultimately not received as a result of the vendor agreeing, several yea...
No. The consideration in respect of the disposal determined under former paragraph 160ZD(1)(a) of the ITAA 1936, is not reduced by that provision if some of the monies are ultimately not received because that provision, by itself, does not allow such a reduction.
In 1995 the taxpayer entered into a contract for the sale of an asset to an unrelated purchaser. The selling price under the contract was payable in ten equal annual payments with interest on the unpaid balance from time to time. The contract was completed on the day it was entered into, and at that time, the vendor wa...
Summary: Where the proceeds from the disposal of an asset in 1995 are payable by instalments over time, they constitute money or an entitlement to money, and thus, the full amount receivable forms part of the 'consideration in respect of the disposal of the asset' under former paragraph 160ZD(1)(a) of the ITAA 1936. If...
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Year ended 30 June 1995
Income Tax Assessment Act 1936 subsection 160ZD(1) paragraph 160ZD(1)(a) section 160ZF
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2003635
ATO ID 2003/636
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
CGT: Capital proceeds payable by instalments - non-receipt rule
Where the 'consideration in respect of the disposal of an asset' is payable by instalments over time, does former section 160ZF of the Income Tax Assessment Act 1936 (ITAA 1936) apply to later reduce that consideration if some of the monies are ultimately not received as a result of the vendor agreeing, several years a...
No. Former section 160ZF of the ITAA 1936 does not apply to reduce the consideration in respect of the disposal of an asset if the vendor later agrees to a reduction in the amount owing.
In 1995 the taxpayer entered into a contract for the sale of an asset to an unrelated purchaser. The selling price under the contract was payable in ten equal annual payments with interest on the unpaid balance from time to time. The contract was completed on the day it was entered into, and at that time, the vendor wa...
Summary: Former subsection 160ZF(1) of the ITAA 1936 applies, in certain circumstances, to reduce the consideration in respect of the disposal of an asset where the whole or a part of the consideration has not been, and is not likely to be, received. As a result, the capital gain arising from the disposal would accordi...
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Year ended 30 June 1995
Income Tax Assessment Act 1936 section 160ZF subsection 160ZF(1) subsection 160ZF(2)
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2003636
ATO ID 2003/774
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital Gains Tax: capital proceeds - shares held in escrow
Are shares received for the sale of a CGT asset included in the capital proceeds for the sale under subsection 116-20(1) of the Income Tax Assessment Act 1997 (ITAA 1997) if the shares are subject to a deed of escrow which imposed a restriction on dealing in the shares?
Yes. The restrictions on dealing in the shares imposed by the deed of escrow do not prevent them being property received in respect of the sale and therefore capital proceeds under paragraph 116-20(1)(b) of the ITAA 1997. This means the value of the shares at the time of the sale must be taken into account in working o...
The taxpayer sold the assets of their business in the 1999-2000 income year. Consideration received by the taxpayer for the sale included shares in the company that purchased the business. On settlement the shares were registered in the taxpayer's name. However, it was a condition of the issue of the shares to the taxp...
Summary: The sale of the taxpayer's business caused CGT event A1 in section 104-10 of the ITAA 1997 to happen. The capital proceeds from a CGT event are the total of the money and the market value of other property received in respect of the event: subsection 116-20(1) of the ITAA 1997. The market value of other proper...
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Year ended 30 June 2000
Income Tax Assessment Act 1997 section 104-10 subsection 116-20(1) paragraph 116-20(1)(b)
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2003774
ATO ID 2010/55
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital gains tax: Australian source capital gains made by a resident trust for CGT purposes
Is the trustee of a resident trust for CGT purposes assessable under paragraph 98(3)(a) of the Income Tax Assessment Act 1936 (ITAA 1936) in relation to an individual non-resident beneficiary's share of the net income of a trust estate that is attributable to capital gains arising from the sale, in Australia, of shares...
Yes. The trustee is assessable under paragraph 98(3)(a) of the ITAA 1936 because:
The taxpayer is the trustee of a resident trust for CGT purposes. The trust is not a fixed trust as defined in subsection 995-1(1) of the Income Tax Assessment Act 1997 (ITAA 1997). A beneficiary of the trust is an individual who was a non-resident throughout the income year. The beneficiary was presently entitled to a...
Summary: A resident trust for CGT purposes must include in the calculation of its net capital gain, capital gains and capital losses from CGT events happening to its worldwide assets. The net capital gain is then included in the trust's net income calculated in accordance with subsection 95(1) of the ITAA 1936. Broadly...
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Year ended 30 June 2007
Income Tax Assessment Act 1997 section 855-15 subsection 855-25(1) subsection 855-40(3) subsection 995-1(1)
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID201055
ATO ID 2004/920
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital Gains Tax: portfolio transfer of general insurance liabilities - acquisition of asset by transferor as against transferee
Does a general insurer, upon a full portfolio transfer, acquire a CGT asset, as against the transferee, for the purposes of Parts 3-1 and 3-3 of the Income Tax Assessment Act 1997 (ITAA 1997) where the insurer undertook a full portfolio transfer by entering into a scheme for the transfer or amalgamation of insurance bu...
No. The general insurer does not acquire a CGT asset for the purposes of Parts 3-1 and 3-3 of the ITAA 1997, upon a full portfolio transfer, where the full portfolio transfer was undertaken in accordance with Division 3A of Part III of the Insurance Act and the portfolio transfer results in the general insurer having n...
The transferor is a general insurance company for the purposes of section 995-1 of the ITAA 1997 and the Insurance Act. The transferor undertook a full portfolio transfer by entering into a scheme for the transfer or amalgamation of insurance business under Division 3A of Part III of the Insurance Act (the scheme), whe...
Summary: In Federal Commissioner of Taxation v. Orica Limited (1998) 194 CLR 500; 98 ATC 4494; (1998) 39 ATR 66 (the Orica Case ) the taxpayer (Orica) entered into an agreement with the Melbourne Metropolitan Board of Works (MMBW) whereby MMBW agreed to assume Orica's obligations to repay the principal amounts due on d...
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Year ended 30 June 2004
Income Tax Assessment Act 1997 Part 3-1 Part 3-3 section 995-1
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null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2004920
ATO ID 2004/936
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital Gains Tax: consequences of barring estate tail
Are there any capital gains tax (CGT) implications when a taxpayer, who owns an estate in fee tail in a property, bars the tail and obtains an estate in fee simple in the property?
No. There are no CGT implications when an estate in fee tail is barred. The owner of the property is not taken to have acquired any asset for the purposes of Division 109 of the Income Tax Assessment Act 1997 (ITAA 1997) when the fee tail is barred.
As a result of the death of an individual before 20 September 1985, the taxpayer acquired an estate in fee tail in a property that the deceased person had owned at the time of their death. The taxpayer wishes to bar the fee tail and obtain an estate in fee simple in the property. Once the taxpayer has obtained the fee ...
Summary: Under the deceased's will the taxpayer obtained an estate in fee tail in a property. An estate in fee tail is an interest in property which is less than a fee simple. An estate in tail can only descend to lineal descendants of the donee. If the line ended, then the estate would revert to the original donor or ...
null
Year ended 30 June 2005
Income Tax Assessment Act 1997 Division 104 subsection 104-10(5) Division 109 section 128-15 subsection 128-15(2)
(including Determinations) Taxation Determination TD 93/37
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2004936
ATO ID 2003/46
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital Gains Tax: CGT event - poker machine entitlement acquired by a NSW hotelier
Did a CGT event happen under Division 104 of the Income Tax Assessment Act 1997 (ITAA 1997) when a NSW hotelier acquired the initial allocation of a poker machine entitlement under paragraph 15(1)(a) of the Gaming Machines Act 2001 (NSW)?
No. There was no CGT event under Division 104 of the ITAA 1997 when the hotelier acquired the initial allocation of a poker machine entitlement under paragraph 15(1)(a) of the Gaming Machines Act 2001 (NSW).
Prior to the commencement of the Gaming Machines Act 2001 (NSW) (Gaming Machines Act), hoteliers in NSW were authorised to hold poker machines under the Liquor Act 1982 (NSW) (Liquor Act). On the commencement of the Gaming Machines Act, an initial allocation of poker machine entitlements was made under paragraph 15(1)(...
Summary: Legal rights fall within the definition of 'CGT asset' at subsection 108-5(1) of the ITAA 1997. The rights pertaining to each approved poker machine, kept in a hotel, for which a poker machine entitlement was allocated, were effectively carried over from the Liquor Act to the Gaming Machines Act. This was faci...
null
Year ended 30 June 2002
Income Tax Assessment Act 1997 Division 104 subsection 108-5(1)
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID200346
ATO ID 2003/551
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital Gains Tax: foreign exchange gains or losses
Does the definition of Capital Gains Tax (CGT) asset include bank accounts denominated in a foreign currency so that deposits or withdrawals will be subject to the provisions of Parts 3-1 and 3-3 of the Income Tax Assessment Act 1997 (ITAA 1997)?
Yes. Bank accounts denominated in a foreign currency are CGT assets and the provisions in Parts 3-1 and 3-3 of the ITAA 1997 apply to any deposits or withdrawals made by Australian residents to the bank accounts.
An Australian resident subsidiary of an offshore parent company acts as a retailer for goods produced by various subsidiaries of the Group and has acted as a 'banker' for the Group. The Australian resident subsidiary has a United States dollar (USD) bank account and a USD short-term deposit account. These accounts are ...
Summary: Under section 108-5 of the ITAA 1997, foreign currency is a CGT asset. However, bank accounts denominated in a foreign currency are not foreign currency but rather a chose in action, or more specifically a debt (or debts), denominated in a foreign currency. The depositing of foreign currency into a bank accoun...
null
Year ended 31 March 1997 Year ended 31 March 1998 Year ended 31 December 1998 Year ended 31 December 1999 Year ended 31 December 2000 Year ended 31 December 2001 Year ended 31 December 2002
Income Tax Assessment Act 1997 section 103-20 section 104-25 section 108-5 section 112-30 subsection 960-50(6)
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2003551
ATO ID 2003/595
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital Gains Tax: assignment of fixtures attached to land
For the purposes of Parts 3-1 and 3-3 of the Income Tax Assessment Act 1997 (ITAA 1997), did the taxpayer acquire ownership of fixtures separately from the leasehold interest in the land to which the fixtures were attached?
No. The taxpayer acquired only one asset for the purposes of Parts 3-1 and 3-3 of the ITAA 1997 - rights under a contract.
A contract for the sale of business was entered into between two entities. Under that contract: The purchaser/lessee has no right to remove the fixtures and must surrender them for their market value at the termination of the lease.
Summary: Although the contract of sale between the parties evidences an intention to transfer ownership of the fixtures to the purchaser, an issue arises as to whether there was a transfer of those fixtures at law or in equity. Fixtures are chattels that are annexed to the land and are treated in law as part of the lan...
null
Year ended 30 June 2003
Income Tax Assessment Act 1997 Part 3-1 Part 3-3
(including Determinations) Taxation Determination TD 93/86
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2003595
ATO ID 2011/26
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital gains tax: assignment of renewable energy certificates
Are there any consequences under Part 3-1 of the Income Tax Assessment Act 1997 (ITAA 1997) for the prospective owner of a small generation unit or a solar water heater, if they use their right to create a renewable energy certificate (REC) to acquire the unit or heater?
No, there are no consequences under Part 3-1 of the ITAA 1997 in these circumstances for the prospective owner of the generation unit or solar water heater.
You have contracted to have a solar power generation unit installed. The unit is an eligible small generation unit for the purposes of the Renewable Energy (Electricity) Act 2000 (the REE Act) Following your purchase and installation of the generation unit a statutory right arises under the REE Act entitling you as the...
Summary: The right to create RECs is a CGT asset. The right arises under the REE Act (Taxation Determination TD 1999/77). CGT event A1 happens if a change in ownership occurs from you to another entity, whether because of some act or event or by operation of law (subsection 104-10(2) of the ITAA 1997). The transfer of ...
null
Year ended 30 June 2011
Income Tax Assessment Act 1997 subsection 104-10(2)
(including Determinations) Taxation Determination TD 1999/77
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID201126
ATO ID 2010/72
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital gains tax: trustee ceasing to hold an asset on trust and commencing to hold it in its own capacity - CGT event A1
Does CGT event A1 in section 104-10 of the Income Tax Assessment Act 1997 ( ITAA 1997) happen if a company ceases to hold a CGT asset in its capacity as trustee of a trust and commences to hold the asset in its own capacity?
Yes. CGT event A1 in section 104-10 of the ITAA 1997 happens because there is a change in ownership of the asset from one entity (the company acting in its capacity as trustee) to another entity (the company acting in its own capacity).
The trustee of a unit trust holds a CGT asset on trust. The trustee is an Australian resident and is a company limited by shares. As part of a restructure, the trustee ceases to hold the asset on trust and commences to hold the asset in its own capacity as a company. The unit holders under the restructure exchange thei...
Summary: CGT event A1 in section 104-10 of the ITAA 1997 happens if there is a disposal of a CGT asset. Under subsection 104-10(2) of the ITAA 1997, a disposal of a CGT asset occurs if there is a change in ownership of the asset from one entity to another entity. The term 'entity' is defined in section 960-100 of the I...
null
Year ended 30 June 2010
Income Tax Assessment Act 1997 section 104-10 subsection 104-10(2) Subdivision 124-N section 960-100 paragraph 960-100(1)(b) subsection 960-100(3)
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID201072
ATO ID 2010/210
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
CGT event A1: partnership becomes corporate limited partnership
Does CGT event A1 in subsection 104-10(1) of the Income Tax Assessment Act 1997 (ITAA 1997) happen to a partnership asset when a partnership converts to a limited partnership that satisfies the definition of corporate limited partnership in section 94D of the Income Tax Assessment Act 1936 (ITAA 1936)?
No, CGT event A1 does not happen as the conversion does not result in a change of ownership for the partnership asset.
A partnership carrying on a business made an application to be a limited partnership and was registered as a limited partnership under the relevant State legislation.
Summary: CGT event A1 happens if you dispose of a CGT asset (subsection 104-10(1) of the ITAA 1997). Subsection 104-10(2) of the ITAA 1997 provides that you dispose of a CGT asset if a change in ownership occurs from you to another entity, whether because of some act or event or by operation of law. Under the scheme of...
null
Year ended 30 June 2010
Income Tax Assessment Act 1997 subsection 104-10(1) subsection 104-10(2)
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2010210
ATO ID 2009/129
CAUTION: This is an edited and summarised record of a Tax Office decision. This record is not published as a form of advice. It is being made available for your inspection to meet FOI requirements, because it may be used by an officer in making another decision. This ATOID provides you with the following level of prote...
Capital gains tax: land vested in a statutory trustee for sale, CGT event A1 or CGT event E1?
Does CGT event A1 in section 104-10 of the Income Tax Assessment Act 1997 (ITAA 1997) happen if the Supreme Court of Queensland makes an order pursuant to section 38 of the Property Law Act 1974 (Qld) appointing statutory trustees for the sale of a co-owned property?
Yes. CGT event A1 in section 104-10 of the ITAA 1997 will happen in respect of the property on the appointment of the statutory trustees.
A commercial property situated in Queensland was owned by two companies as tenants in common. As a result of a disagreement between the co-owners as to their future use of the property, one of the co-owners applied to the Supreme Court of Queensland for an order under section 38 of the Property Law Act 1974 (PLA) for t...
Summary: CGT event A1 happens if you dispose of a CGT asset: subsection 104-10(1) of the ITAA 1997. You dispose of a CGT asset if a change of ownership occurs from you to another entity, whether because of some act or event or by operation of law: subsection 104-10(2) of the ITAA 1997. If the disposal is not made under...
null
Year ended 30 June 2009
Income Tax Assessment Act 1997 section 104-10 subsection 104-10(1) subsection 104-10(2) subsection 104-10(3) subsection 104-55(1) subsection 116-20(1)
null
null
null
null
false
https://www.ato.gov.au/law/view/document?docid=AID/AID2009129
End of preview.

Australian Taxation Office Legal Database — Machine-Readable

60,000+ ATO rulings, determinations, and private advice. Structured CSV. RAG-ready on day one.

The ATO Legal Database spans 15 years of Australian tax law — private advice, interpretative decisions, public rulings, and compliance guidelines. It's all public. It's all messy HTML. Getting it into a format an LLM can actually use takes weeks of data engineering.

This dataset skips that. Every document is one CSV row. Every logical section is its own column. Source URLs included.

Files are updated automatically on weekdays when new ATO documents are detected.

If this dataset saves you time, consider supporting the project:

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Contents


Dataset Splits

Split Document Type Est. Documents Coverage
edited_private_advice Edited Private Advice (EPA) — all years in one file ~50,000 2011–present
ato_interpretative_decisions ATO Interpretative Decisions (ATO ID) ~10,000 All years
public_rulings Public Rulings & Determinations ~2,000 All years
practical_compliance_guidelines Practical Compliance Guidelines (PCG) ~200 All years

Quick Start

import pandas as pd
# Load one split
df = pd.read_csv("edited_private_advice_all.csv")
# Filter to active (non-archived) documents
active = df[df["Is_Archived"] == False]
print(active[["Authorisation_Number", "Subject", "Date_of_Advice"]].head())

Multi-value fields (legislative references, ruling periods, related documents) use | as the internal delimiter:

# Explode pipe-delimited legislative references into one row per provision
provisions = (
    active["Relevant_Legislative_Provisions"]
    .str.split(" | ")
    .explode()
    .str.strip()
    .value_counts()
)
print(provisions.head(10))

Schema

Encoding conventions

Convention Detail
Multi-value delimiter | (space-pipe-space) within a single cell
Empty values Empty string "" — never NULL or N/A
Booleans True / False
Dates Verbatim as published by the ATO — no normalisation

1. Edited Private Advice (edited_private_advice)

Private rulings issued to individual taxpayers, anonymised and edited for publication.

Column Type Nullable Description
Authorisation_Number string No Primary key. ATO-assigned identifier, e.g. 1-2ABCDEF.
Date_of_Advice string Yes Date the private advice was issued, e.g. 1 July 2024. Blank for older documents.
Subject string Yes Single-sentence topic description, e.g. Capital gains tax — main residence exemption.
Ruling string Yes All Q&A pairs concatenated: Q1: [text] | A1: [text] | Q2: [text] | A2: [text].
Ruling_Period string Yes Income years the ruling applies to: Year ending 30 June 20XX | Year ending 30 June 20XX.
Date_Scheme_Commenced string Yes Date the relevant arrangement commenced. Blank when not stated.
Relevant_Facts_and_Circumstances string Yes Full facts section, collapsed to single-space prose.
Relevant_Legislative_Provisions string Yes Act/section references, e.g. ITAA 1997 s104-10 | ITAA 1997 s116-20.
Reasons_for_Decision string Yes Summary plus all sub-headings: Summary: [text] | Detailed Reasoning - [Sub-heading]: [text].
Is_Archived boolean No True if the document carries an archival disclaimer.
Source_URL string No Full URL, e.g. https://www.ato.gov.au/law/view/document?docid=AEA/1-2ABCDEF.

2. ATO Interpretative Decisions (ato_interpretative_decisions)

Edited summaries of Tax Office internal decisions, released under FOI obligations.

Column Type Nullable Description
ATO_ID_Number string No Primary key, e.g. ATO ID 2010/101.
Status string Yes FOI/editorial status note as published.
Title string Yes Short title of the decision.
Issue string Yes The question put to the ATO.
Decision string Yes The ATO's answer.
Facts string Yes Relevant facts and circumstances.
Reasons_for_Decision string Yes Reasoning supporting the decision.
Date_of_Decision string Yes Date the decision was made, e.g. 2010/06/15.
Year_of_Income string Yes Income year to which the decision relates.
Legislative_References string Yes Pipe-separated act/section references.
Related_Public_Rulings_and_Determinations string Yes Related TR/TD/IT references, pipe-separated.
Related_ATO_Interpretative_Decisions string Yes Related ATO ID numbers, pipe-separated.
Subject_References string Yes ATO subject taxonomy tags, pipe-separated.
Business_Line string Yes ATO business line that issued the decision.
Is_Archived boolean No True if the document is archived/superseded.
Source_URL string No Full URL, e.g. https://www.ato.gov.au/law/view/document?docid=AID/2010/101.

3. Public Rulings & Determinations (public_rulings)

Binding public rulings (TR, TD, IT, CR, PR) and legislative instruments issued by the Commissioner.

Column Type Nullable Description
Document_Reference string No Primary key, e.g. TR 2024/1.
Document_Type string No Full type name, e.g. Ruling, Determination.
Document_Type_Code string No Short code: TR, TD, IT, CR, PR, etc.
Title string Yes Full document title.
Status string Yes Final, Draft, Withdrawn.
Date_of_Issue string Yes Publication date, e.g. 1 July 2024.
Date_of_Effect string Yes Date from which the ruling applies.
Date_of_Withdrawal string Yes Withdrawal date, if applicable.
What_This_Ruling_Is_About string Yes Scope statement from the document.
Class_of_Entities_or_Scheme string Yes Who or what the ruling applies to.
Ruling string Yes The operative ruling paragraphs.
Examples string Yes Worked examples from the ruling.
Appendix_Explanation string Yes Explanatory appendix text.
Other_Appendices string Yes Any additional appendices.
Previous_Rulings string Yes Documents this ruling replaces, pipe-separated.
Related_Rulings string Yes Related ATO publications, pipe-separated.
Legislative_References string Yes Act/section references, pipe-separated.
Case_References string Yes Court/tribunal cases cited, pipe-separated.
Subject_References string Yes ATO subject taxonomy tags, pipe-separated.
ATO_References string Yes Internal ATO reference numbers.
Is_Withdrawn boolean No True if the ruling has been withdrawn.
Source_URL string No Full URL, e.g. https://www.ato.gov.au/law/view/document?docid=TR/TR_2024/1.

4. Practical Compliance Guidelines (practical_compliance_guidelines)

Guidelines explaining how the ATO will administer specific areas of tax law, including safe harbours.

Column Type Nullable Description
PCG_Number string No Primary key, e.g. PCG 2020/2.
Document_Type string No Final PCG or Draft PCG.
Title string Yes Full document title.
Status string Yes Current, Withdrawn, Draft.
Date_of_Issue string Yes Publication date.
Date_of_Effect string Yes Date from which the guideline applies.
Date_of_Withdrawal string Yes Withdrawal date, if applicable.
Replaces string Yes Predecessor document(s), e.g. PS LA 2011/18.
Related_Rulings_and_Determinations string Yes Related ATO publications, pipe-separated.
Legislative_References string Yes Act/section references, pipe-separated.
Summary string Yes One-paragraph executive summary.
Purpose_and_Scope string Yes Who the guideline applies to and why.
Background string Yes Context and policy history.
Compliance_Approach string Yes The ATO's stated enforcement stance, including safe harbour thresholds.
Examples string Yes Worked examples from the document.
Appendices string Yes Appendix content.
Other_Sections string Yes Any additional named sections.
Compendium_Reference string Yes Reference to associated ruling compendium, if any.
Is_Archived boolean No True if the document is archived.
Is_Draft boolean No True if the document is a draft.
Source_URL string No Full URL, e.g. https://www.ato.gov.au/law/view/document?docid=PCG/PCG_2020/2.

Use Cases

  • RAG pipelines — each row is a self-contained retrieval unit; chunk on Ruling, Reasons_for_Decision, or Compliance_Approach
  • Legal NLP — classification, summarisation, and named-entity recognition on Australian tax law
  • Legislative graph construction — explode Legislative_References to build provision co-citation networks
  • Compliance tooling — filter on Document_Type_Code + Is_Withdrawn == False to surface current binding obligations

Support the Project

This dataset is free. If it saves you time on data engineering, a coffee is appreciated:

☕ Buy Me a Coffee


Source & Licensing

Data sourced from the ATO Legal Database (© Commonwealth of Australia). ATO public legal documents are made available under the Creative Commons Attribution 3.0 licence. This structured dataset is published by SimpleLex under the same terms.


Citation

@dataset{simplelex_ato_rulings_2026,
  author    = {SimpleLex},
  title     = {ATO Tax Legal Rulings — Structured AI Dataset},
  year      = {2026},
  publisher = {Hugging Face},
  url       = {https://huggingface.co/datasets/simplelex/Aussie-Tax-Legal-Database}
}

Terms of Service

Last updated: May 2026

What this product is

The Aussie Tax Legal Database is a structured dataset of publicly available legal documents published by the Australian Taxation Office (ATO) at ato.gov.au. Documents include Edited Private Advice, Public Rulings, Determinations, ATO Interpretive Decisions, and Practical Compliance Guidelines, compiled into machine-readable CSV format.

Permitted use

You may use this dataset for any lawful purpose, including research, analysis, building applications, and commercial projects. You do not need to ask permission. Attribution is appreciated but not required for the compilation itself.

Source material and copyright

The underlying ATO documents are published under the Creative Commons Attribution 3.0 Australia licence. The ATO retains copyright in the original documents. This dataset is a structured compilation and does not claim copyright in the original source material.

Not legal or tax advice

Nothing in this dataset constitutes legal or tax advice. Documents are reproductions of publicly available ATO materials provided for informational purposes only. Always consult a registered tax agent or legal professional for advice about your specific situation.

Accuracy and currency

We make no warranties about the completeness, accuracy, or currency of the data. ATO documents may be updated, withdrawn, or replaced after the dataset was last scraped. Always verify against the ATO Legal Database for official or time-sensitive purposes.

No liability

To the maximum extent permitted by Australian law, simplelex accepts no liability for any direct, indirect, or consequential loss arising from use of or reliance on this dataset.

Changes

We may update these terms at any time. Continued use of the dataset following an update constitutes acceptance of the revised terms.

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