29 Jun 066 CGT: When are beneficiaries and terms of 2 trusts the same? - TR 2006/4This final Taxation Ruling was released on 28 June 2006. It was previously released in draft form as TR 2005/D15: see 2005 TAXVINE No 38 (17) (30 September 2005). Its full title is "Income tax: capital gains: meaning of the words 'the beneficiaries and terms of both trusts are the same' in paragraphs 104-55(5)(b) and 104-60(5)(b) of the Income Tax Assessment Act 1997". The Ruling explains the circumstances in which the beneficiaries and terms of two trusts are considered to be the same for the purpose of applying an exception to CGT events E1 (a trust is created over a CGT asset) and E2 (a CGT asset is transferred to an existing trust).
For a copy of TR 2006/4 go here