Foreign exchange fluctuation treatment as operating revenue or expense favoured the assessee; prospective safe harbour notification did not apply.

Foreign exchange fluctuation income or loss was examined for whether it formed part of operating revenue or operating expense for the assessment year in question. The Revenue's reliance on the Safe Harbour Notification dated 18 September 2013 failed because the notification operated prospectively and did not govern the period under review. Earlier Tribunal-supported decisions also favoured the assessee's treatment of the item. The issue was therefore answered in favour of the assessee and against the Revenue, and no substantial question of law arose.

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Issues: Whether income or loss arising from foreign exchange fluctuation was to be treated as part of the operating revenue or operating expense for the assessment year under appeal.

Analysis: The Revenue's reliance on the Safe Harbour Notification dated 18 September 2013 was held to be of no assistance as the notification operated prospectively. The issue was also covered by earlier decisions referred to by the Tribunal, which supported the assessee's position.

Conclusion: The question was answered in favour of the assessee and against the Revenue, and no substantial question of law arose.

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