Nearly two years since the ATO released their draft ruling LCR 2019/D3 to clarify how the 1 July 2018 amendments were to be applied in respect of NALE, we see the release of the final version of the ruling, as LCR 2020/2. The final version of the ruling was expected to address issues raised in many submissions by industry on the draft ruling and whilst it has addressed these issues, not all will be satisfied with the ATO’s responses. In particular, the ATO’s response to the issue of whether there is a nexus between expenditure that is general in nature and all of the fund’s income is not the outcome that industry has welcomed.
