TR 2023/4dc1.

Written by Claude Haiku 4.5 from the extracted text on 27 Feb 2026. It can miss or misread redacted and scanned pages. Check the source before relying on it.

This is a draft consolidated taxation ruling (TR 2023/4DC1) consolidating guidance on employee classification for income tax and superannuation guarantee purposes. The ATO is updating the original TR 2023/4 and incorporating the withdrawn Superannuation Guarantee Ruling SGR 2005/1 into a new Appendix 2. Once finalised, the addendum will be a public ruling under the Taxation Administration Act 1953. The ruling provides that taxpayers correctly relying on it will not incur additional tax, penalties, or interest on matters covered. For superannuation guarantee purposes, while not formally binding on the Commissioner, the ruling indicates relevant factors in the Commissioner's discretion regarding penalty imposition if she later takes a less favourable view. The document outlines the framework for determining "employee" status by examining the totality of the relationship between worker and engaging entity, addressing evidence of contract formation, variations, sham