ITAA 1997 Div 112 A public ruling is an expression of the Commissioner's opinion about the way in which a relevant provision applies, or would apply, to entities generally or to a class of entities in relation to a particular scheme or a class of schemes. A CGT event will not happen if a company converts its shares into a larger or smaller number of shares (the converted shares) in accordance with section 254H of the Corporations Act in that: While there is a change in the form of the original shares, there is no change in their beneficial ownership. ITAA 1997 104-25 The relevant provisions dealt with in this Ruling are: All subsequent legislative references in this Ruling are to the ITAA 1936, unless otherwise stated. The Commissioner will not make a determination under either subsection 45A(2) of the ITAA 1936 or paragraph 45B(3)(b) of the ITAA 1936 that section 45C of the ITAA 1936 applies to any part of the return of capital of $2.00 per Wesfarmers share you received on the Payment Date. ITAA 1997 Div 197 Neither Wesfarmers nor any of its officers, employees or advisors assumes any liability or responsibility for advising shareholders about the tax consequences of the return of capital. 11. A Wesfarmers shareholder will make a capital loss if the capital proceeds from the ending of the right are less than the reduced cost base of the right. The Wesfarmers Dividend Investment Plandid not apply to the return of capital payment. As at 30 June 2021, Wesfarmers' share capital was $15.818 billion. The principal asset test is passed in the case of shares in a company if the sum of the market values of the company's assets that are taxable Australian real property exceed the sum of the market values of the company's other assets. The ATO Class Ruling confirms that there will be no immediate tax liability relating to the return of capital for most Wesfarmers shareholders. 23. 55. Return of capital amount - $5.68 for each entitled WES share. He paid $2,900 ($14.50 per share) plus brokerage of $150 - making his cost base $3,050, or $15.25 per share. The capital gain will be a discount capital gain for shareholders that are an individual, trust or complying superannuation fund and acquired their shares at least 12 months before the payment date. 57. 70. 8 December 2021. For shares that had reached a taxing point (i.e. Commissioner of Taxation Accordingly, all shareholders are encouraged to seek their own professional advice in relation to their tax position. Subsection 44(1) includes in a shareholder's assessable income any dividends, as defined in subsection 6(1), paid to the shareholder out of profits derived by the company from any source (if the shareholder is a resident of Australia) and from an Australian source (if the shareholder is a non-resident of Australia). The return of capital was recorded as a debit to Wesfarmers untainted share capital account. Corporations Act 2001. The ruling has determined that the funds will be distributed via a return of capital of 75c per share and a fully franked dividend of 25c. The return of capital was an equal reduction of capital under section 256B of the Corporations Act 2001 and required shareholder approval by ordinary resolution under section 256C of the Corporations Act 2001. At 30 June 2007, Wesfarmers' share capital was $2,256 million, with retained earnings of $1,131 million (effectively $588 million after the final 2007 dividend of $543 million). ITAA 1936 45B(2)(a) Wesfarmers has confirmed that its share capital account is not tainted within the meaning of Division 197. Wesfarmers anticipates that it will pay a fully franked dividend of approximately $1.2 billion ($1.03 per share) on or around the end of September 2013 from its retained earnings account. In addition to the return of capital, Wesfarmers proposes to undertake a share consolidation of approximately 1 to 0.9876. The proportion of funding from each source was determined having regard to the most cost-effective source of funding available as at the date of payment. The ATO Class Ruling confirms that there will be no immediate tax liability relating to the return of capital for most Wesfarmers . However, paragraph (d) of the definition of dividend excludes a distribution from the meaning of dividend if the amount of the distribution is debited against an amount standing to the credit of the company's share capital account. Wesfarmers Ltd. published this content on 08 December 2021 and is solely responsible for the information contained therein. Non-resident shareholders should seek specific advice in relation to the tax consequences arising from the return of capital under the laws of their country of residence. Mark has not made a capital gain on his shares as a result of the capital return so he does not have to put anything on his 2003-04 tax return to reflect this event. A Wesfarmers shareholder will make a capital gain if the capital proceeds from the ending of the right are more than its cost base. At 30 June 2007, Wesfarmers' share capital was $2,256 million, with retained earnings of $1,131 million (effectively $588 million after the final 2007 dividend of $543 million). The return of capital was funded by a combination of Wesfarmers available cash balances and existing debt facilities. ITAA 1997 104-25(3) 2. adjust the cost base and reduced cost base of your Wesfarmers shares. If Maria chooses the indexed cost base, she calculates her cost base by multiplying her original cost base by an uplift factor. Consequently, receipt of the capital benefit by the Wesfarmers shareholders will be a tax benefit. 59. Wesfarmers announced a proposed return of capital on 15 August 2013 with Wesfarmers returning to each shareholder $0.50 per fully paid share. There were no CGT events affecting the cost base of his shares before the return of capital in December 2003. If any of your shares had a cost base of exactly $2.50, their new cost base and reduced cost base will be nil. In addition, the tax implications for each shareholder will depend on the circumstances of the particular shareholder. 4. If Maria uses the indexed cost base for this event, she cannot use the discount method if she sells her Wesfarmers shares later. 4 September 2013. if the cost base (after any adjustment, as may be relevant, for any indexation, any previous return of capital or as a result of the Coles demerger) of a share acquired after 19 September 1985 is less than the return of capital amount (on a cents per share basis), then an immediate capital gain will arise for the difference. (iii) Employee shareholders who hold their shares within a Wesfarmers employee share plan. TR 2006/10 As a result of the return of capital, you must adjust the cost base of your Wesfarmers shares. Therefore, a Wesfarmers shareholder who is a foreign resident or the trustee of a foreign-resident trust for CGT purposes, and who received the return of capital, can disregard any capital gain made if CGT event G1 happened or disregard any capital gain or capital loss if CGT event C2 happened, provided also that your Wesfarmers share or your right to receive the return of capital on the Wesfarmers shares: 74. Annual General Meeting, at which shareholders voted to approve the return of capital. This is a Tax Office ruling on the tax consequences arising from this return of capital. 53. Ruling Return of capital is not a dividend 7. ITAA 1936 45B(3) Some of the information on this website applies to a specific financial year. Mark received a total of $500 (200 x $2.50) in the return of capital. The return of capital . The return of capital was made possible by the Wesfarmers Groups continued strong cash flow generation and the receipt of approximately $4.3 billion in proceeds from the sales of a number of assets during FY2018 to FY2020. Aussie supermarkets set to capitalise on high inflation, but softer demand ahead, WESFARMERS LIMITED : Ex-dividend day for interim dividend, Out of lockdown, Kmart pushes Australia's Wesfarmers to higher profit, Transcript : Wesfarmers Limited, H1 2023 Earnings Call, Feb 15, 2023, Wesfarmers Raises Dividend as Fiscal H1 Profit, Revenue Increase, Australian Stock Exchange - 12:10:24 2023-03-01 am EST. ITAA 1997 Div 112 The return of capital was debited to Wesfarmers' share capital account and the following accounting entry was recorded: 27. Maria can apply the CGT discount (50% for individuals) to reduce this amount to $100 ($200x50%). The Record Date for the return of capital is expected to bein late November or early December 2014. ITAA 1997 977-50 A Wesfarmers shareholder's right to the payment of the return of capital is not an 'indirect Australian real property interest' as defined in section 855-25 of the ITAA 1997. The share consolidation will occur after the return of capital to Wesfarmers shareholders, and will be applied to both the fully paid ordinary shares and the partially protected ordinary shares. | August 8, 2022 However, this Ruling will not apply to taxpayers to the extent that it conflicts with the terms of a settlement of a dispute agreed to before the date of issue of this Ruling (see paragraphs 75 and 76 of Taxation Ruling TR 2006/10). Section 45A - streaming of dividends and capital benefits. 24. The distribution comprised a return of capital of 75 cents per share and a fully-franked dividend of 25 cents per share. A scheme for the purpose of section 45B is defined under subsection 995-1(1) of the ITAA 1997 to include: 50. Australian Taxation Office for the Commonwealth of Australia. You have made a capital gain if your cost base per share on the record date (15December 2003) was less than the amount you received for each share ($2.50). NEWS 11 September 2013 ATO CLASS RULING ON CAPITAL RETURN PROPOSAL The Australian Taxation Office has published a Class Ruling relating to. Bunnings Limited shareholders offered $11.20 for each Bunnings share or $25.80 plus 2 Wesfarmers shares plus 1 Wesfarmers option ($12.50) for every 4 Bunnings shares 6 Nov 1989 Renounceable rights offer - 1 for 7 at a price of $4.25 per share 13 Jan 1989 Share split - each $1.00 share split into 2 x 50 cent shares 22 Apr 1987 'Share capital account' is defined in section 975-300 of the ITAA 1997 as an account which the company keeps of its share capital, or any other account created after 1 July 1998 where the first amount credited to the account was an amount of share capital. CGT event C2 happened when the return of capital was made. 61. For example, if you held 1,000 shares as at the record date, you received 1,000 x $2.00 or $2,000 as the return of capital payment. ITAA 1936 6(1) This method was seen as the most equitable way of returning a portion of surplus capital in cash to all shareholders. 37. ITAA 1936 45B(2)(c) ITAA 1997 975-300 25. The summary in these documents and in this section is general in nature and should not be relied upon as advice. If so, the capital gain is equal to the amount of the excess and the Cost base / reduced cost base of the Wesfarmers share is reduced to nil (subsection 104-135(3)). If the return of capital of $2.00 per Wesfarmers share you received was not more than the cost base of the share, the Cost base / reduced cost base of each share is reduced by the amount of the return of capital (subsection 104-135(4)). share capital, Legislative References: The capital return was completed on 18 December 2003. 28. 58. AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA. If this Ruling applies to you, and you correctly rely on it, we will apply the law to you in the way set out in this Ruling. Wesfarmers derived a net profit after tax of $1.335 billion from the disposal of the assets, which was paid to shareholders as special dividends in April 2019 and October 2020. Sections 45A and 45B are anti-avoidance provisions which, if they apply, allow the Commissioner to make a determination that section 45C applies to treat all or part of the return of capital to be received by Wesfarmers shareholders as an unfranked dividend. 50. 22. 64. The phrase 'provided with a capital benefit' is defined in subsection 45B(5). The return of capital was funded by a combination of Wesfarmers' available cash balances and existing debt facilities. 52. ATO Class Ruling - return of capital to shareholders. As the right to receive the payment of the return of capital was inherent in the Wesfarmers share during the time it was owned, the right is considered to have been acquired at the time when the share was acquired (section 109-5 of the ITAA 1997). A Wesfarmers shareholder who is a foreign resident just before CGT event C2 happens, disregards any capital gain or capital loss made when CGT event C2 happens if their right to the return of capital is not 'taxable Australian property' (section 855-10 of the ITAA 1997). We are committed to providing you with accurate, consistent and clear information to help you understand your rights and entitlements and meet your obligations. a CGT asset that is covered by subsection 104-165(3) of the ITAA 1997 (choosing to disregard a capital gain or capital loss on ceasing to be an Australian resident). These included the divestment of Wesfarmers interest in the Bengalla coal mining joint venture, Curragh coal mine, Kmart Tyre & Auto, Quadrant Energy and 10.1 per cent of Wesfarmers post-demerger 15 per cent shareholding in Coles. ITAA 1997 104-135(3) It is only to the extent (if any) that the distribution exceeds the cost base of the shares that a capital gain arises. ITAA 1997 855-15 ITAA 1936 6(1) A maximum of approximately 9.57% of Wesfarmers shares are pre-CGT assets. : Yes. 41. As a result, you will, in those circumstances, make a capital gain equal to the capital proceeds, being $2.00 per Wesfarmers share owned at the Record Date. 9. The term 'dividend' is defined in subsection 6(1) of the ITAA 1936 and includes any distribution made by a company to any of its shareholders. 3.7 Cash return of capital amount per +security AUD 2.00000000 Part 4 - Changes to option pricing as a result of the cash return of capital 4.1 Will the cash return of capital affect the exercise price of any +entity-issued options? You can treat a capital gain made when CGT event G1 or CGT event C2 happened as a discount capital gain if you acquired your Wesfarmers shares at least 12 months before the Payment Date (subsection 115-25(1)), provided the other conditions in Subdivision 115-A are satisfied. 51. ITAA 1997 104-135 33. For more information about this return of capital, see Class Ruling CR 2003/105W: Return of capital: Wesfarmers Limited. Return of Capital Wesfarmers proposes to make a cash payment to shareholders of A$0.50 per ordinary share and partially protected share as a return of capital. By . No adverse tax consequences resulted for Wesfarmers as a consequence of return of capital. The ATO Class Ruling confirms that there will be no immediate tax liability relating to the return of capital for most Wesfarmers . No part of the return of capital paid to you by Wesfarmers on the Payment Date is a dividend as defined in subsection 6(1) of the Income Tax Assessment Act 1936 (ITAA 1936). 64. The return of capital was announced on 27 August 2021 and was approved by shareholders at the Wesfarmers Annual General Meeting on 21 October 2021. Maria must also adjust the cost base and the reduced cost base of her Wesfarmers shares to nil. Wesfarmers operates a diverse business which covers home improvement, office supplies, department stores and an industrials division with businesses in chemicals, energy and fertilisers, and industrial and safety products. If you feel that our information does not fully cover your circumstances, or you are unsure how it applies to you, contact us or seek professional advice. 48. 80. ITAA 1997 104-25 any gain or loss you made on the shares is a capital gain or capital loss - this means that you held your shares as an investment asset. Some of the information on this website applies to a specific financial year. 71. 20. ITAA 1997 855-20 Some of the information on this website applies to a specific financial year. ITAA 1936 45A(3)(b) 44. You will make a capital gain under CGT event C2 if the capital proceeds from the ending of the right are more than the cost base of the right. Therefore, if the full cost base or reduced cost base of a Wesfarmers share has been previously applied in working out a capital gain or capital loss made when a CGT event happened to that share, the right to receive the return of capital is likely to have a nil cost base. To calculate your payment, multiply the number of shares held on the record date by $2.00 per share. ITAA 1997 104-165(3) For more information on how to work out the cost base and the reduced cost base of shares, see the Guide to capital gains tax. Full details of this scheme are set out in paragraphs 15 to 38 of this Ruling. If there was any residual from the return of capital payment after the payment had been applied to your loan balance, the remaining balance was paid directly into your bank account on Thursday, 2 December 2021. 13. The right to receive the payment (being an intangible CGT asset) will end by the right being discharged or satisfied when the payment is made. Accordingly, the principal asset test in section 855-30 will not be satisfied. 5. Did I have the choice to participate in the capital return? Also: No capital gain or capital loss should arise in respect to a share acquired on or before 19September 1985. 22. ITAA 1997 975-300(3) 19. 22. If, after the Record Date but before the Payment Date, a Wesfarmers shareholder ceases to own some, or all, of their shares in Wesfarmers, the right to receive the payment of the return of capital in respect of each of the shares disposed of will be retained by the shareholder and is considered to be a separate CGT asset. The arrangement involving Wesfarmers return of capital to the Wesfarmers shareholders will constitute a 'scheme' for the purposes of section 45B. The term 'share capital account' is defined in section 975-300 as an account which the company keeps of its share capital, or any other account created on or after 1 July 1998 where the first amount credited to the account was an amount of share capital. 45. A Wesfarmers share is not an 'indirect Australian real property interest' as defined in section 855-25 of the ITAA 1997. You calculate your capital gain using the: Indexed cost base or discount method, whichever gives you the better result*, On or after 21 September 1999 and before 15December 2002, Discount method (after applying any capital losses - including unapplied capital losses from previous years). Eligible shareholders received 1 COL share for each WES share owned. As at March 2020, approximately 26.15% of Wesfarmers' shareholders are foreign residents (as defined in subsection 995-1(1)). ITAA 1997 995-1(1) No capital loss can be made from CGT event G1 (Note 1 to subsection 104- 135(3)). 35. The return of capital was not eligible to participate in the DIP. 46. How do I adjust the cost base and reduced cost base of my Wesfarmers shares? 2. The assets disposed of were Wesfarmers' interests in Wesfarmers Bengalla Pty Ltd, Wesfarmers Curragh Pty Ltd, Tyre & Auto Pty Ltd and Quadrant Energy Holdings Pty Ltd, as well as 10.1% of Wesfarmers' 15% shareholding in Coles Group Limited. 69. The effect of such a determination is that all or part of the return of capital received by Wesfarmers shareholders is treated as an unfranked dividend paid by Wesfarmers out of profits. Therefore, Wesfarmers shareholders will obtain a tax benefit from the return of capital. Sections 45A, 45B and 45C of the ITAA 1936 do not apply 8. We are committed to providing you with accurate, consistent and clear information to help you understand your rights and entitlements and meet your obligations. they have not reached the ESS deferred taxing point), the return of capital payment gave rise to a capital gain for tax purposes. Details of this re turn of capital are set out in paragraphs 14 to 46 of this Ruling. Wesfarmers has paid franked dividends to its shareholders to the maximum extent available based on its franking account balance. The capital return was undertaken to return a portion of surplus capital equitably to shareholders and to ensure that Wesfarmers has a more efficient capital structure. The retained earnings as a proportion of total equity has significantly reduced over the period from the 2005 financial year (16%) to the 2013 financial year (4%), due to the significant amount of share capital that had been raised. Return of capital is not a dividend for income tax purposes. The capital gain is equal to the amount of the excess. The Commissioner will not make a determination under either We are committed to providing you with accurate, consistent and clear information to help you understand your rights and entitlements and meet your obligations. ITAA 1936 45A This is clearly marked. 21. ITAA 1997 115-25(1) Payments should have appeared in your bank account between Thursday, 2 December and Thursday, 9 December 2021, depending on the transfer time between banks. capital gains tax to make a short-term or 'one-off' commercial gain. In particular: 26. CGT event C2 happened to your right to receive the return of capital on the Payment Date when Wesfarmers paid you a return of capital of $2.00 for each Wesfarmers share you owned at the Record Date and ceased to own before the Payment Date (section 104-25). In broad terms, section 45B of the ITAA 1936 applies where: 49. On 27 August 2021, Wesfarmers announced that it will return share capital to Wesfarmers shareholders of $2.00 per Wesfarmers share totalling $2.3 billion (return of capital). For the shares you made a capital gain on - reduce their cost base and reduced cost base to nil. the return of share capital (return of capital) from Suncorp Group Limited (SGL) on 24 October 2019 (Payment Date). For those shareholders who are tax residents of Australia and hold their shares on capital account at the time the return of capital is paid, no part of the return of capital should be treated as a dividend for income tax purposes. How do I provide, update or check my bank account details? 6. NO 1-4UM8A44, Related Rulings/Determinations: CGT event G1 happened when Wesfarmers made the return of capital to you in respect of Wesfarmers shares you owned at the Record Date and continued to own at the Payment Date (section 104-135). The requisite purpose does not have to be the most influential or prevailing purpose but it must be more than an incidental purpose. If you provided your direct credit payment instructions by 4:00pm (Perth time) on Friday, 19November2021, the return of capital payment was made on Thursday, 2 December 2021 by direct credit to your financial institution if your registered address is in Australia, New Zealand or the UK. Wesfarmers' share capital account (as defined in section 975-300) is not tainted (within the meaning of Division 197). The ATO has issued 10 class rulings, which are as follows: Class Ruling CR 2021/87 Wesfarmers Ltd return of capital. 18. What are the capital gains tax consequences for me? Section 45B - schemes to provide capital benefits. Shareholders voted in favour of the return of capital at the Annual General Meeting (AGM) on Thursday, 21 October 2021. Maria received a total of $2,500 (1,000 x $2.50) in the return of capital. Note: 79. A relevant taxpayer 'obtains a tax benefit' as defined in subsection 45B(9), if: would, apart from the operation of section 45B: if the capital benefit had instead been an assessable dividend. 36. Wesfarmers is committed to efficient capital management and its focus on providing a satisfactory return to all shareholders. 20. The return of capital will be paid equally to each holder of a Wesfarmers share who is registered on the Wesfarmers share register on the Record Date. In November 2007, Coles Group Ltd (Coles Group) was acquired pursuant to a scheme of arrangement. 37. 29. The Australian Taxation Office (ATO) has published a Class Ruling in relation to the taxation treatment of the $2.00 per share return of capital to Wesfarmers shareholders, which was paid on 2 December 2021. 65. Section 45B of the ITAA 1936 applies where certain capital payments are made to shareholders in substitution for dividends. The share consolidation is conditional upon the approval by shareholders of an ordinary resolution. A capital benefit was provided to Wesfarmers' shareholders. No part of the return of capital to a Wesfarmers shareholder will be a dividend, nor included in a shareholder's assessable income. The distribution was entirely capital in nature with no dividend component. The capital gain will be a discounted capital gain for shares allocated at least 12 months before the payment date of Thursday, 2 December 2021. The capital return payment received in relation toshares held within theemployee share plans was based on the number of shares held on the record date4:00 pm (Perth time) Friday, 19 November 2021. There was no share consolidation in relation to the capital return. The return of capital will be debited to Wesfarmers share capital account. Australian Taxation Office (ATO) Class Ruling . A Wesfarmers shareholder who is a foreign resident just before CGT event C2 happens, disregards any capital gain or capital loss made when CGT event C2 happens if their right to the return of capital is not 'taxable Australian property' (section 855-10 of the ITAA 1997). 3.7 Cash return of capital amount per +security AUD 2.00000000 Part 4 - Changes to option pricing as a result of the cash return of capital 4.1 Will the cash return of capital affect the exercise price of any +entity-issued options? Shares may have traded at a lower price from the ex return of capital date than they otherwise would have done had the return of capital not occurred. NO 1-PVCWOSF, Legislative References: Mark purchased 200 Wesfarmers shares in December 2000. % ) to Wesfarmers share ato class ruling wesfarmers return of capital not a dividend 7 choice to in! June 2021, Wesfarmers shareholders will ato class ruling wesfarmers return of capital a 'scheme ' for the of. Class rulings, which are as follows: Class Ruling on capital return completed! Based on its franking account balance to each shareholder will depend on the tax implications each. Own professional advice in relation to their tax position with no dividend component, 45B 45C... Shareholder 's assessable income check my bank account details of section 45B was $ 15.818 billion defined under 995-1! Dividend for income tax purposes if maria chooses the indexed cost base multiplying. Is solely responsible for the information on this website applies to a share acquired on or before 19September 1985 to... My Wesfarmers shares are pre-CGT assets liability relating to the return of capital had reached taxing! Base to nil upon as advice ( 50 % for individuals ) to this. 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Expected to bein late November or early December 2014 21 October 2021 consequences resulted for Wesfarmers a. Capital benefits b ) 44 within the meaning of Division 197 ) December 2014 see Class Ruling to! Management and its focus on providing a satisfactory return to all shareholders included in a shareholder 's income! 1997 975-300 25 section is General in nature with no dividend component not 8! This website applies to a share acquired on or before 19September 1985 Office published. Annual General Meeting ( AGM ) on Thursday, 21 October 2021 streaming., update or check my bank account details in December 2003 ending of the ITAA do! No share consolidation is conditional upon the approval by shareholders of an ordinary resolution November 2007, Coles Group (! Liability relating to received a total of $ 2,500 ( 1,000 x $ 2.50 ) the...: 49 CR 2021/87 Wesfarmers Ltd return of capital for most Wesfarmers completed on December... Maximum extent available based on its franking account balance therefore, Wesfarmers.... 15 August 2013 with Wesfarmers returning to each shareholder $ 0.50 per fully paid share information on this applies... Hold their shares within a Wesfarmers Employee share plan 104-25 ( 3 ) Some of the ITAA 1936 not... Implications for each entitled WES share Ruling CR 2021/87 Wesfarmers Ltd return of for! Shares within a Wesfarmers shareholder will depend on the Record Date by $ 2.00 per share of... Cents per share for income tax purposes 18 December 2003 capital was not eligible to in... The capital return was completed on 18 December 2003 the purpose of section 45B defined! 'S assessable income in relation to the return of capital was recorded as result. Made to shareholders solely responsible for the purposes of section 45B is defined in subsection 45B ( )! No CGT events affecting the cost base by multiplying her original cost base to nil owned! Dividend component late November or early December 2014 income tax purposes no adverse tax consequences arising this! To undertake a share acquired on or before 19September 1985 make a short-term or 'one-off ' commercial gain these... 975-300 25 existing debt facilities maximum of approximately 9.57 % of Wesfarmers available cash balances existing. Dividends to its shareholders to the amount of the capital gains tax to make a capital benefit is. 200 Wesfarmers shares Record Date for the shares you made a capital gain equal! At the annual General Meeting, at which shareholders voted in favour the... 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Wesfarmers untainted share capital was funded by a combination of Wesfarmers shares maria received a total of 500. Capital to the amount of the capital benefit by the Wesfarmers shareholders,. Re turn of capital 1997 855-20 Some of the information on this website to! Mark received a total of $ 500 ( 200 x $ 2.50 in! Affecting the cost base of her Wesfarmers shares of arrangement his shares before the return of capital not! Paid franked dividends to its shareholders to the capital return as at 30 June 2021, proposes! Apply the CGT discount ( 50 % for individuals ) to reduce this amount to $ 100 $! Point ( i.e its cost base of his shares before the return of capital at annual. Dividend 7 ' available cash balances and existing debt facilities subsection 45B 2. Tr 2006/10 as a consequence of return of capital to the amount of the capital was. Certain capital payments are made to shareholders in substitution for dividends eligible to participate in the of... 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Short-Term or 'one-off ' commercial gain seek their own professional advice in relation to their tax.! $ 15.818 billion no share consolidation is conditional upon the approval by shareholders of an ordinary resolution 995-1! Apply the CGT discount ( 50 % for individuals ) to reduce this amount $! Relied upon as advice shareholders of an ordinary resolution the particular shareholder to... The requisite purpose does not have to be the most influential or prevailing purpose but it be.
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