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TD 92/179 - Income tax: Co A, in the course of carrying on its investment and sharetrading business, issues to its shareholders, at non-refundable premiums, warrants on shares held in another Co which grant to the warrantholders the right to purchase the underlying shares at a fixed price within a certain period of time The nature of the warrants is similar to that of call options Do the premiums form part of Co A's assessable income under subsection 6-5 of the Income Tax Assessment Act 1997, and are they derived in the years in which the warrants are issued?

[1992] ATOTD 179

Australian Taxation Office

Australia - Commonwealth

Legislation Cited

Legislation Name	Provision
Income Tax Assessment Act 1936 (Cth)
Income Tax Assessment Act 1997 (Cth)
Taxation Administration Act 1953 (Cth)

Cases and Articles Cited

Case Name	Citation(s)	Court	Jurisdiction †	Date	Full Text		Citation Index
Inland Revenue Commissioners v Rolls-Royce Ltd	[1962] 1 WLR 425		United Kingdom	circa 1962	LexisNexis / Westlaw		11
Californian Copper Syndicate v Harris	(1904) 5 Tax Cas 159; 6 F 894		United Kingdom	circa 1904			193
Rolls-Royce Ltd v Jeffrey	1 WLR 425		United Kingdom	circa 1904	LexisNexis / Westlaw		9

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