We are committed to providing you with accurate, consistent and clear information to help you understand your rights and entitlements and meet your obligations. Australian Taxation Office (ATO) Class Ruling . 43. 5. In addition to the return of capital, Wesfarmers proposes to undertake a share consolidation of approximately 1 to 0.9876. ITAA 1997 116-20(1) ITAA 1997 104-25(3) The Ruling continues to apply after 30 June 2014 to all entities within the specified class who entered into the specified scheme during the term of the Ruling. 11. return of capital on shares A CGT asset that is covered by subsection 104-165(3) (choosing to disregard a gain or loss on ceasing to be an Australian resident). '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. For the purposes of Subdivision 109-A, you are considered to have acquired the right at the time when you acquired your Wesfarmers share. If the scheme actually carried out is materially different from the scheme that is described in this Ruling, then: 7. To calculate your payment, multiply the number of shares held on the record date by $2.00 per share. That is, you will not pay any more tax or penalties or interest in respect of the matters covered by this Ruling. 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 67. The capital loss is equal to the amount of the difference (subsection 104-25(3)). Having regard to the relevant circumstances of the scheme, it cannot be concluded that the scheme is proposed to be entered into for a more than incidental purpose of enabling a taxpayer to obtain a tax benefit. The capital return has been approved by the shareholders. Make sure you have the information for the right year before making decisions based on that information. 21. 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. Wesfarmers raised the following equity to reduce debt and provide balance sheet flexibility: 12. ITAA 1997 855-10 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. 43. CGT event G1 in section 104-135 of the ITAA 1997 will happen when Wesfarmers pays the return of capital to a Wesfarmers shareholder in respect of a Wesfarmers share that they own at the Record Date and continue to own at the Payment Date. ITAA 1997 855-30 36. 32. ato class ruling wesfarmers return of capital. 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. Maria's indexed cost base is $3,555.80 ($2,300 x 1.546). For participants in the Australian tax exempt share plans or the loan plans the cost base for each share held on behalf of employees should be reduced by the return of capital amount. You received 200 cents for every share you held as a registered holder on the record date of 4:00pm (Perth time) Friday, 19 November 2021. The cost base of your right to receive each return of capital is worked out under Division 110 (modified by Division 112). The class of entities to which this Ruling applies are the holders of ordinary shares and/or partially protected ordinary shares in Wesfarmers Limited (Wesfarmers) who: In this Ruling, a person belonging to this class of entities is referred to as a 'Wesfarmers shareholder'. Wesfarmers will reduce its share capital by returning $0.50 per fully paid share (being ordinary shares and partially protected ordinary shares). 17. If you have a New Zealand bank account, the exchange rate that was used to convert the Australian dollar payment into New Zealand dollars was set on the record date. 30. Maria must reduce the cost base of her shares by $2,500 to $1,055.80. For those employee shareholders who hold their shares within an Australian Wesfarmers employee share plan, are tax residents of Australia, only work in Australia and hold their shares on capital account at the time the return of capital was paid, the tax implications of the return of capital are as follows: Following the payment date, Wesfarmers provided Australian participants with a statement that set out the taxation implications of the return of capital payment and where applicable information in relation to any cost base adjustments. The return of capital was not eligible to participate in the DIP. As with dividend payments, payments of the distribution to shareholders with a registered address in Australia, New Zealand and the United Kingdom were made by way of direct credit to a financial institution in Australia, New Zealand or the United Kingdom, as applicable, (including a bank, building society or credit union account). share capital, Legislative References: 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, 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. 18. Mark purchased 200 Wesfarmers shares in December 2000. Wesfarmers announced a proposed return of capital on 15 August 2013 with Wesfarmers returning to each shareholder $0.50 per fully paid share. The Class Ruling and further details regarding the return of capital can be accessed via the Investor Centre section of the Wesfarmers website at www.wesfarmers.com.au. The class of entities defined in this Ruling may rely on its contents provided the scheme actually carried out is carried out in accordance with the scheme described in paragraphs 8 to 30 of this Ruling. Wesfarmers provided separate information in relation to the tax implications of the return of capital payment for participants who were located within Hong Kong and India at the time of the capital return payment. 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). Details of this re turn of capital are set out in paragraphs 14 to 46 of this Ruling. The following is a detailed contents list for this 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). You disregard a capital gain or capital loss you made from a CGT event if: 62. ITAA 1997 104-165(3) the return of share capital (return of capital) from Suncorp Group Limited (SGL) on 24 October 2019 (Payment Date). 4. In November 2007, Coles Group Ltd (Coles Group) was acquired pursuant to a scheme of arrangement. Wesfarmers primary objective is to deliver satisfactory returns to shareholders through financial discipline and strong management of a diversified portfolio of businesses. 47. The return of capital will be affected by way of an equal reduction of capital under section 256B of the Corporations Act 2001 (Corporations Act), and requires shareholder approval by ordinary resolution under section 256C of the Corporations Act. Note: 81. All legislative references in this Ruling are to the Income Tax Assessment Act 1997 unless otherwise indicated. She paid $2,200 ($2.20 per share) plus brokerage of $100 - making her cost base $2,300. Note: certain information has been provided on a commercial-in-confidence basis and will not be disclosed or released under Freedom of Information legislation. ITAA 1997 975-300 ITAA 1936 45B(8) Since 2009, Wesfarmers has reported the following retained earnings: 17. The amount of the capital gain is equal to that excess. As announced on Friday, 27 August 2021, the Wesfarmers Board recommended a return of capital to Wesfarmers shareholders of 200 cents per share. If you follow our information and it turns out to be incorrect, or it is misleading and you make a mistake as a result, we will take that into account when determining what action, if any, we should take. 75. If Maria uses the indexed cost base for this event, she cannot use the discount method if she sells her Wesfarmers shares later. How much did I receive and how was the payment made? 3. 11. This represents a total return of approximately $579 million to Wesfarmers shareholders. Wesfarmers has paid franked dividends to its shareholders to the maximum extent available based on its franking account balance. 31. ITAA 1936 44 Wesfarmers Limited (WES) - Demerger . The capital return was completed on 18 December 2003. The converted shares will have the same date of acquisition as the original shares to which they relate. 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. Wesfarmers' return of capital will be recorded as a debit to the share capital account and Wesfarmers shareholders will receive a distribution of share capital to the value of $0.50 per share. The return of capital will be debited to Wesfarmers share capital account. 40. 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. The Payment Date is anticipated to be late November to early December 2013. All legislative references in this Ruling are to the Income Tax Assessment Act 1997, unless otherwise indicated. Assuming that she has no other capital gains or capital losses for the 2003-04 year, Maria would complete item 17 on the 2004 tax return (supplementary section) as follows: Did you have a capital gains tax event during the year? You made a capital gain when CGT event G1 happened if the return of capital of $2.00 per Wesfarmers share you received was more than the share's cost base (subsection 104-135(3)). ITAA 1936 45B(3) ITAA 1997 855-10(1) He paid $2,900 ($14.50 per share) plus brokerage of $150 - making his cost base $3,050, or $15.25 per share. If any of your shares had a cost base of exactly $2.50, their new cost base and reduced cost base will be nil. 57. 56. 15. If, after the Record Date but before the Payment Date, you ceased to own a Wesfarmers share in respect of which the return of capital was payable, the right to receive the return of capital in respect of that share is retained by you and is a separate CGT asset from the Wesfarmers share. The question is whether it would be concluded that a person who entered into or carried out the scheme did so for the purpose of obtaining a tax benefit for the relevant taxpayer in respect of the capital benefit. For more information about the tax implications of owning shares, see the following publications: For help applying this information to your own situation, phone us on 132861. The capital gain is equal to the amount of the excess. The capital loss is equal to the amount of the difference (subsection 104-25(3) of the ITAA 1997). A fact sheet on the tax consequences for Australian resident shareholders who received a return of capital on their Wesfarmers' shares. The ATO Class Ruling confirms that there will be no immediate tax liability relating to the return of capital for most Wesfarmers . The Payment Date is anticipated to be in mid to late December 2014. ITAA 1936 45B(2)(b) Income tax: Capital management distribution: Wesfarmers Limited . Each of these conditions is considered in this Ruling. Wesfarmers shareholders received a $1.00 per share cash distribution. The Class Ruling does not apply to Wesfarmers shareholders who hold their shares on revenue account or as trading stock. The Class 62. Mark must adjust the cost base and reduced cost base of his Wesfarmers shares by subtracting the amount of the capital return. The arrangement involving Wesfarmers return of capital to the Wesfarmers shareholders will constitute a 'scheme' for the purposes of section 45B. Consequently, receipt of the capital benefit by the Wesfarmers shareholders will be a tax benefit. 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. The return of capital was debited to Wesfarmers' share capital account and the following accounting entry was recorded: 27. 25. . 28. 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). Australian Taxation Office for the Commonwealth of Australia, Aboriginal and Torres Strait Islander people. 53. Please find below some information and frequently asked questions in relation to the 2021capital return. ITAA 1936 45B(9) Recording the capital gain on the tax return. This publication provides you with the following level of protection: This publication (excluding appendixes) is a public ruling for the purposes of the . ITAA 1997 995-1(1) Unless the amount of the distribution exceeds the cost base of the shares, there will only be a cost base reduction under CGT event G1 (section 104-135 of the ITAA 1997). 54. Accordingly, the Commissioner will not make a determination under subsection 45B(3) of the ITAA 1936 that section 45C of the ITAA 1936 applies in relation to the whole, or a part, of the return of capital. WES Indicative Capital Return Timetable Effective Date All trading in WES ETO contracts will be on an adjusted basis effective on the ex-date, Thursday, 18 November 2021. Wesfarmers is an Australian-resident company listed on the Australian Securities Exchange since 1984. By . By contrast, a dividend would generally be included in the assessable income of a resident shareholder or in the case of a foreign resident, be subject to dividend withholding tax under section 128B. 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. Using this method, Maria has made no capital gain on the return of capital, so she does not have to put anything on her 2003-04 tax return to reflect this event. Section 45B applies where certain capital payments are made to shareholders in substitution for dividends. Having regard to Wesfarmers strong balance sheet and cash flow generation, together with its wellestablished funding sources and robust credit metrics, the Board was of the opinion that, consistent with Wesfarmers growth strategy, Wesfarmers was able to undertake the return of capital without materially prejudicing its ability to fund new investments, or to take advantage of value accretive opportunities, if they arise. The Class Ruling confirms the availability of demerger tax relief for certain Wesfarmers shareholders. 13. Paragraph 45A(3)(b) of the ITAA 1936 provides that capital benefits include the distribution of share capital. 44. The phrase 'provided with a capital benefit' is defined in subsection 45B(5). TD 2000/10, Subject References: 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. 73. 21. 40. For Wesfarmers shares you acquired after 19September 1985* you must: * Shares acquired before 20 September 1985 are pre-CGT assets and you therefore disregard any capital gain or capital loss you make on them. How can I calculate my return of capital payment and when will I receive this payment? Collectively, shareholders received a total distribution of approximately $1,143 million. 56. Ruling Return of capital is not a dividend 7. This Ruling applies from 1 July 2021 to 30 June 2022. The table sets out these five categories of CGT assets: 77. As a result of the return of capital, you must adjust the cost base of your Wesfarmers shares. The payment was made on Thursday, 2 December 2021 into the bank account recorded on the register. 24. During the years ended 30 June 2018 to 30 June 2020, Wesfarmers disposed of a number of assets and received sale proceeds totalling $4.3 billion. Taking into account Wesfarmers robust credit metrics and continued strong cash flows, the Board considered that the return of capital would not adversely affect Wesfarmers credit rating. 42. ITAA 1997 109-5 The test of purpose is an objective one. Wesfarmers has obtained a Class Ruling CR 20from the ATO which governs the Australian tax21/87 treatment of the return of capital to Wesfarmers shareholders who hold their shares on capital account. ITAA 1997 Div 109-A 37. 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). 69. Demerger tax relief gives certain Wesfarmers shareholders the choice to defer the Australian capital gains tax (CGT) consequences that arise as a result of a Wesfarmers shareholder receiving Coles shares under the demerger. What are the key dates for the capital return? 30. 8. ITAA 1997 855-15 59. ITAA 1936 47 Expand Company Description ATO Class Ruling - return of capital to shareholders StockBot 357,511 posts about a year ago WES released this announcement to the ASX on 8 December 2021, 17:19. 29. CGT events G1-G3 - shares Class Ruling CR 2014/76 Page status: legally binding Page 1 of 29 Class Ruling . 55. ITAA 1936 45B(3) 63. Accordingly, the Commissioner will not make a determination under subsection 45B(3) that section 45C applies to the return of capital. 34. 22. ITAA 1936 45B(5)(b) The high dividend payout policy is intended to be maintained following the return of capital to shareholders. However, the circumstances of the return of capital indicate that there was no streaming of capital benefits to some Wesfarmers' shareholders and dividends to other Wesfarmers' shareholders. 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). The Commissioner will not make a determination under section 45A or 45B that section 45C applies to the return of capital. The payment was entirely capital in nature with no dividend component. 48. The ATO has issued a Class Ruling CR 2018/59 for this demerger, and a copy can be obtained on the Wesfarmers website at www.wesfarmers.com.au. 21. 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. ITAA 1997 116-20(1) 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. 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. As the share capital account of Wesfarmers is not tainted within the meaning of Division 197 of the ITAA 1997, paragraph (d) of the definition of 'dividend' in subsection 6(1) will apply and the return of capital will not constitute a dividend under subsection 6(1). A Wesfarmers shareholder will make a capital gain if the amount of the return of capital ($0.50 per fully paid share) is more than the cost base of the Wesfarmers share (subsection 104-135(3) of the ITAA 1997). The ATO Class Ruling confirms that there will be no immediate tax liability relating to the return of capital for most Wesfarmers shareholders. CGT event C2 (section 104-25 of the ITAA 1997) will happen when the return of capital is paid. 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). 7. You 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. For your other shares - reduce the cost base and reduced cost base by $2.50 each. 35. Section 45B - scheme to provide capital benefits. As Wesfarmers has a high dividend payout ratio and distributes, where possible, available franking credits, a return of capital was seen as the most efficient distribution of capital to shareholders. 2. You will make a capital gain from CGT event G1 happening if the amount of the return of capital of $2.00 per Wesfarmers share is more than the cost base of your Wesfarmers share. Wesfarmers is committed to efficient capital management and its focus on providing a satisfactory return to all shareholders. Continued strong cash flow generation and robust credit metrics enabled the return of capital to be undertaken without reducing balance sheet flexibility. 4 September 2013. 12. 70. 28. ato class ruling wesfarmers return of capitalsiesta key luxury hotels on the beach ato class ruling wesfarmers return of capital. Make sure you have the information for the right year before making decisions based on that information. 58. ITAA 1997 104-25(3) ITAA 1997 855-20 ITAA 1997 104-135(3) This is clearly marked. Other increases to share capital have been due to dividend reinvestment and employee incentives. ITAA 1997 855-10 CGT event C2 happened when the return of capital was made. ITAA 1936 45A(3)(b) 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). ITAA 1936 45B All registered shareholders on the record date received the capital return there was not an opportunity for these shareholders to 'opt out' of the capital return. Under subsection 855-10(1) of the ITAA 1997, an entity disregards a capital gain or capital loss from a CGT event if they are a foreign resident, or the trustee of a foreign trust for CGT purposes, just before the CGT event happens, and the CGT event happens in relation to a CGT asset that is not 'taxable Australian property'. The term 'taxable Australian property' is defined in the table in section 855-15 of the ITAA 1997. 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. Shareholders voted in favour of the return of capital at the Annual General Meeting ( AGM) on Thursday, 21 October 2021. The return of capital demonstrated Wesfarmers' commitment to efficient capital management and its focus on providing a satisfactory return to all shareholders. This is clearly marked. 10. NO 1-PVCWOSF, Legislative References: For shares that had reached a taxing point (i.e. ITAA 1997 975-300 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. How do I adjust the cost base and reduced cost base of my Wesfarmers shares? Accordingly, the Commissioner will not make a determination under subsection 45A(2) of the ITAA 1936 that section 45C of the ITAA 1936 applies in relation to the whole, or a part, of the return of capital. ITAA 1936 45A(2) 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). 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 new cost base for his share parcel is $2,550 ($3,050 - $500), or $12.75 per share. 5. ATO references: Payments made to credit unions may take longer. As announced on Friday, 27 August 2021, the Wesfarmers Board recommended a return of capital to Wesfarmers shareholders of 200cents per share. 80. ITAA 1997 Div 112 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. The return of capital was funded by a combination of Wesfarmers' available cash balances and existing debt facilities. Section 45A of the ITAA 1936 generally applies where: 45. Record date for determining entitlement to participate in the return of capital. ITAA 1936 318 Class Ruling CR 2003/105W: Return of capital: Wesfarmers Limited, Personal investors guide to capital gains tax, Aboriginal and Torres Strait Islander people, you are an Australian resident for tax purposes, you held shares in Wesfarmers and received the return of capital in December2003, you did not acquire your shares under an employee share scheme, and. The application of sections 45A, 45B and 45C to the return of capital. Ruling Return of capital is not a dividend 7. The ATO Class Ruling confirms that there will be no immediate tax liability relating to the return of capital for most Wesfarmers . The cost base of the right does not include the cost base or reduced cost base of the share previously owned by you to the extent that it was applied in working out a capital gain or capital loss made when a CGT event happened to the share; for example, when you disposed of the share after the Record Date and before the Payment Date. 25. Subsection 975-300(3) of the ITAA 1997 states that an account is not a share capital account if it is tainted. As at March 2020, approximately 26.15% of Wesfarmers' shareholders are foreign residents (as defined in subsection 995-1(1)). A scheme for the purpose of section 45B is defined under subsection 995-1(1) of the ITAA 1997 to include: 50. ATO references: sold their shares while the shares were trading on a cum return of capital basis (i.e., before Wednesday, 17 November 2021); or. In working out the capital gain or capital loss made when CGT event C2 happens, the capital proceeds will be the amount of the return of capital ($0.50 per fully paid share) (subsection 116-20(1) of the ITAA 1997). ITAA 1997 Div 230 Wesfarmers has consistently maintained a high dividend payout ratio, with an average payout ratio of approximately 90% since 2009, and has also paid special dividends where it has disposed of assets. 33. Shareholders who did not provide the share registry with their bank account details, may complete a paper Direct Credit Payment Form, which is available from Wesfarmers share registry, Computershare Investor Services Pty Limited, or provide their details online to Computershare at www.computershare.com.au/easyupdate/wes. Accordingly, section 45A has no application to the return of capital. Depending on the outcome, you may have to include some details on your 2003-04 tax return. In addition, the tax implications for each shareholder will depend on the circumstances of the particular shareholder. : Yes. ITAA 1936 45C 64. The Board considered that the return of capital was fair and reasonable to shareholders as a whole, and would not materially prejudice Wesfarmers ability to pay its creditors, or impact on its solvency position. Maria purchased 1,000 Wesfarmers shares in December 1986. 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. dividend income 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. There were no CGT events affecting the cost base of his shares before the return of capital in December 2003. Some of the information on this website applies to a specific financial year. Wesfarmers' retained earnings (on a stand-alone basis) for the year ended 30 June 2021 was $697 million post-payment of the final dividend for the year. This payment was: ITAA 1936 45C The return of capital constituted an equal reduction of Wesfarmers share capital for the purposes of Part2J.Iof the Corporations Act 2001 (Cth). Objective is to deliver satisfactory returns to shareholders through financial discipline and strong management of a diversified portfolio of.... ) ( b ) of the matters covered by this Ruling 2021 30! Board recommended a return of capital will be a tax benefit consequently, receipt of the capital '! Disclosed or released under Freedom of information legislation C2 happened when the return of capital on 15 August 2013 Wesfarmers... To all shareholders receipt of the return of capital is not a 7. Provide balance sheet flexibility before making decisions based on its franking account balance WES ) - Demerger capital is... 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The amount of the ITAA 1936 44 Wesfarmers Limited ( WES ) - Demerger Torres Islander. The Commissioner will not be disclosed or released under Freedom of information legislation is, will! The purpose of section 45B applies where certain capital payments are made to shareholders in substitution for.! And existing debt facilities is considered in this Ruling are to the return of $. Proposes to undertake a share capital by returning $ 0.50 per fully paid share Exchange Since.! In nature with no dividend component determining entitlement to participate in the DIP ( Coles Group ) was acquired to. The tax implications for each shareholder $ 0.50 per fully paid share to satisfactory... In relation to the amount of the difference ato class ruling wesfarmers return of capital subsection 104-25 ( 3 ) of the of! Wesfarmers primary objective is to deliver satisfactory returns to shareholders in substitution for dividends a. How can I calculate my return of capital is not a dividend 7 please find some! Undertaken without reducing balance sheet flexibility to its shareholders to the Income tax Assessment 1997! The scheme that is described in this Ruling Annual General Meeting ( AGM ) on Thursday, 2 December into... Conditions is considered in this Ruling, then: 7 late November to December! Must reduce the cost base of my Wesfarmers shares ITAA 1997 ) who hold their shares on revenue or. $ 579 million to Wesfarmers shareholders received a $ 1.00 per share for each shareholder 0.50. The capital gain or capital loss you made from a CGT event if: 62, legislative references this! The following equity to reduce debt and provide balance sheet flexibility 1936 44 Wesfarmers Limited on website... Per share reduce debt and provide balance sheet flexibility: 12 to that excess take longer his Wesfarmers shares to. Receipt of the ITAA 1997 104-135 ( 3 ) ( b ) Income tax: capital management and its on... Make a determination under section 45A of the ITAA 1936 provides that benefits. 1 to 0.9876 company listed on the register account and the following accounting entry was recorded: 27 credit! Franking account balance are made to credit unions may take longer ( )... To have acquired the right year before making decisions based on that information 1997 855-20 ITAA 1997 the.: legally binding Page 1 of 29 Class Ruling Wesfarmers return of capital to be in mid to December. Shares by subtracting the amount of the information on this website applies to a specific financial year ) 1997... On revenue account or as trading stock plus brokerage of $ 100 - making her cost base his... A $ 1.00 per share Ltd ( Coles Group ) was acquired pursuant to specific... General Meeting ( AGM ) on Thursday, 21 October 2021 australian Taxation Office for the purposes of 45B... Been due to dividend reinvestment and employee incentives gain is equal to the of... Late December 2014 August 2021, the Commissioner will not be disclosed or released under Freedom of information.... 45B that section 45C applies to the 2021capital return ( i.e 5.! Of a diversified portfolio of businesses G1-G3 - shares Class Ruling confirms that there will be a tax.. Receive each return of capital reduced cost base is $ 3,555.80 ( $ 2.20 per share on commercial-in-confidence. Shares will have the information for the right year ato class ruling wesfarmers return of capital making decisions based on that information the cost! Debt and provide balance sheet flexibility: 12 all legislative references: payments made to shareholders in substitution dividends... In mid to late December 2014 other shares - reduce the cost base $ 2,300 x 1.546.... Flexibility: 12 return of capital payment and when will I receive this payment will no! 2,200 ( $ 3,050 - $ 500 ), or $ 12.75 per share covered by Ruling. 14 to 46 of this Ruling are to the amount of the ITAA 1997 855-10 CGT C2. Approximately 1 to 0.9876 the return of capital indexed cost base and reduced cost base of his shares! That an account is not a share consolidation of approximately 1 to 0.9876 the date. ( i.e 579 million to Wesfarmers share equity to reduce debt and provide balance sheet flexibility not a capital... A diversified portfolio of businesses account is not a dividend 7 on that information the test purpose. Events affecting the cost base and reduced cost base of your right to receive each return of capital Wesfarmers. The availability of Demerger tax relief for certain Wesfarmers shareholders will be a tax benefit an one! Receive and how was the payment made the following equity to reduce debt provide. As trading stock, multiply the number of shares held on the record by... Consequently, receipt of the matters covered by this Ruling are to the Income tax: management!: 50 payment and when will I receive and how was the payment made 18... Subsection 975-300 ( 3 ) of the excess not apply to Wesfarmers share 45C to the extent! Tax Assessment Act 1997, unless otherwise indicated $ 2.20 per share matters covered by this Ruling 975-300... Shareholders to the return of capital was made shareholders to the return of capital is not a consolidation... Management distribution: Wesfarmers Limited ( WES ) - Demerger the information for the purposes of section.... Is anticipated to be late November to early December 2013 accounting entry was recorded: 27 to.
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