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Product Ruling PR 2002/142 sets out the Commissioner's opinion on the tax consequences for persons participating in the Clews Road Vineyard Estate Project ('the Project') by entering into Investment, Vineyard Management and Vineyard Lease Agreements for the purpose of carrying on a commercial viticulture project.

We have reviewed the Project and determined that the arrangement, as implemented, is materially different from that described in the Product Ruling for the following reasons: • the 2003 and 2004 Clews Road Establishment Fees, Vines Costs Fee, Irrigation and Trellising Purchase Prices were not payable on entering the Instalment Agreement; and • the 2004 Clews Road Establishment Services and the majority of the trellising services were not completed by 30 June 2004.

As a result, Product Ruling PR 2002/142 has no application as it does not rule on the tax consequences for any taxpayer.

Growers who were accepted to participate in the Project cannot rely on PR 2002/142. However, a Grower may lodge an application for a private ruling in regard to the tax consequences of the Grower's particular circumstances.