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The ATO has issued a Decision Impact Statement in relation to the decision of the Full Court of the Federal Court in FCT v Messenger Press Pty Ltd [2013] FCAFC 77; 2013 ATC 20-400.

The case concerned whether a currency exchange loss was incurred under former Division 3B of ITAA 1936 on the discharge by a company of USD indebtedness to its subsidiary.

The Full Court concluded that no actual exchange of currency is required in order to realise a "currency exchange loss".

The Decision Impact Statement states:

"A number of ATO Interpretative Decisions and references to Division 3B in a Taxation Determination will be withdrawn following this decision. Division 3B was repealed in 2003 and the Commissioner considers that this decision will have a limited ongoing impact on other taxpayers. As a result, there is no intention to replace the withdrawn ATO precedential documents."

For full details of the affected ATOIDs and other rulings, and the administrative procedure to be adopted by the ATO, see the Decision Impact Statement under the heading "Administrative Treatment".


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