The Australian Taxation Office (ATO) has launched a consultation on the implementation of the new Corporate Collective Investment Vehicle (CCIV) regime that commences on 1 July 2022. The new regime is provided for by the Corporate Collective Investment Vehicle Framework and Other Measures Act 2022 (Act No. 8, 2022), which received royal assent (was enacted) on 22 February 2022. As explained in a separate release on the regime:

• a CCIV is:  
  • a type of company limited by shares that is used for funds management;
  • an umbrella vehicle that is comprised of one or more sub-funds and is operated by its single corporate director;
• the objective of the CCIV tax framework is that the general tax treatment of CCIVs and their members aligns with the existing tax treatment of attribution managed investment trusts (AMITs) and their members. Where a CCIV sub-fund trust:
  • meets the AMIT eligibility criteria, it will be taxed as an AMIT under the attribution flow-through tax regime;
  • fails to meet the AMIT eligibility criteria, the CCIV sub-fund trust will be taxed in accordance with general trust provisions, which is consistent with the current outcomes for AMITs;
• investors in CCIVs will generally be taxed as if they had invested directly in the underlying assets.

Click the following link for the consultation, which seeks input from stakeholders to identify, prioritize, and address the administrative and interpretative issues that require support to implement the new CCIV regime.