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On 18 April 2012 the ATO issued Miscellaneous Taxes ruling MT 2012/2 entitled Miscellaneous taxes: application of the income tax and GST laws to deferred transfer farm-out arrangements.

This ruling sets out the Commissioner’s views on the application of the income tax and GST provisions upon entry into a deferred transfer farm-out arrangement as described in the ruling.

In particular, for income tax purposes, the ruling explains the application of the following provisions to deferred transfer farm-out arrangements:

  • the capital gains tax (CGT) provisions
  • the uniform capital allowance (UCA) provisions, and
  • s 6-5, 8-1, 15-2 and 15-40 ITAA 1997.

The ruling was originally released in draft as MT 2011/D2.


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