The thing about Tax Rulings, as I understand them, is they only...

The thing about Tax Rulings, as I understand them, is they only bind the Commissioner, not the tax payer. They state the Commissioners view of the law, which may or may not be right until a court decides.

The ruling relies on the application of Part IVA, which is an anti-avoidance provision of last resort. My understanding, albeit old now, is that Part IVA needs to be applied on individual transactions as it relies on the dominant purpose of the transactor and cannot be applied on a general class basis.

This is not tax advice as I have not been in the game for many many years and things have probably changed since I last looked.

The real question to ask is: How often, and in what circumstance, has the Commissioner applied the approach suggested in TR 2008/1?

You should assess your individual risk with proper professional advice in relation to a contemplated transaction and not necessarily give in to any fear uncertainty and doubt by accepting TR 2008/1 at face value.