Operational Notice
No: 27/2009
10 December 2009
Removal of Non-Resident Interest Withholding Tax on Commonwealth Government Securities
Legislation making Commonwealth Government Securities eligible for exemption from non-resident interest withholding tax (IWT) has come into effect following Royal Assent to the Tax Laws Amendment (2009 Measures No. 5) Act 2009 on 4 December 2009.
Interest payments on Commonwealth Government Securities are now exempt from IWT provided the securities satisfy the public offer test under section 128F of the Income Tax Assessment Act 1936. The following Commonwealth Government Securities on issue are considered to satisfy this requirement:
Treasury Bonds |
||
Coupon Rate (%) |
Maturity Date |
ISIN |
5.25 |
15 August 2010 |
AU300TB01216 |
5.75 |
15 June 2011 |
AU0000XCLWG7 |
5.75 |
15 April 2012 |
AU3TB0000010 |
6.50 |
15 May 2013 |
AU0000XCLWH5 |
6.25 |
15 June 2014 |
AU3TB0000028 |
6.25 |
15 April 2015 |
AU0000XCLWI3 |
6.00 |
15 February 2017 |
AU300TB01208 |
5.25 |
15 March 2019 |
AU300TB01224 |
4.50 |
15 April 2020 |
AU3TB0000036 |
5.75 |
15 May 2021 |
AU0000XCLWM5 |
Treasury Indexed Bonds |
||
Coupon Rate (%) |
Maturity Date |
ISIN |
4.00 |
20 August 2010 |
AU0000XCLWA0 |
4.00 |
20 August 2015 |
AU0000XCLWD4 |
4.00 |
20 August 2020 |
AU0000XCLWE2 |
3.00 |
20 September 2025 |
AU0000XCLWP8 |
The Australian Taxation Office has advised the Australian Office of Financial Management that the Commonwealth Government Securities listed above satisfy the public offer test under subsection 128F(3) of the Income Tax Assessment Act 1936 to the extent that subsection 128F(5) of the Act does not apply.
- Subsection 128F(5) relates to the acquisition of securities by associates of the issuer. The Commonwealth is not aware, and has no grounds to suspect, that any of the securities listed above have been or will be acquired by associates of the Commonwealth in circumstances that would be covered by the provisions of the subsection. Accordingly, the subsection does not apply to these securities.
It continues to be the case that IWT does not apply to Treasury Notes. For further information see Tax Ruling No IT 2054.
The information memoranda for Treasury Bonds and Treasury Indexed Bonds will be updated in coming weeks to reflect the change in relation to IWT.