15 Input Quantity: 1 Endeavour share to every 1 Woolworths share. (e) Cross-border demerger involving transfer of shares of an Indian company. . For a demerger to be tax neutral, demerged undertaking should be transferred on a going concern basis. But they get off to a slow start because there is a weight of sellers wanting to get out upon listing and there is no compelling or urgent reason to buy. Another way to value the parts is to consider the whole. Income earned after the date of succession; Income of the Financial Year in which the succession takes place and the previous year preceding that year, if the predecessor cannot be found or the tax payable cannot be recovered from the predecessor. Wesfarmers has prepared a tax information guide for Australian resident Wesfarmers shareholders. Example Own 1000 WOW as of the Scheme date - received 1000 EDV Shares from the demerger. This is another capital gains tax event for you. By rejecting non-essential cookies, Reddit may still use certain cookies to ensure the proper functionality of our platform. If you had owned your Woolworths shares for more than 12months as at the date you sold your Woolworths shares you can reduce the remaining capital gain (if any) by the 50% CGT discount. Create your myGov account and link it to the ATO, Help and support to lodge your tax return, Occupation and industry specific income and work-related expenses, Residential rental properties and holiday homes, Instalment notices for GST and PAYG instalments, Your obligations to workers and independent contractors, Encouraging NFP participation in the tax system, Australian Charities and Not-for-profits Commission, Departing Australia Superannuation Payment, Small Business Superannuation Clearing House, Annual report and other reporting to Parliament, Complying with procurement policy and legislation. A plausible interpretation is that reference to assessee can cover both a demerged or a resulting company. A capital gains tax event happened when your stapled securities were sold. MAT credit is available as a credit for succeeding 15 years for set-off against the excess of normal tax over MAT. Judicial precedents in the context of amalgamation [74] have held that amalgamation constitutes succession, since post amalgamation, the amalgamating company ceases to exist. Paul has more than 30 years experience in financial services and banking, including 20 years with the Commonwealth Bank Group in senior leadership roles. All prices and analysis at 4 June 2021. If you owned Woolworths shares on 30November 2012 but sold them before 11December 2012, you must include the following amounts in your 201213 tax return: Work out your capital gain or capital loss on the sale of your Woolworths shares by comparing the cost base of your shares and the sale proceeds. You apportion your pre-demerger WOW cost base 85.81% to your post-demerger WOW shares and 14.19% to your EDV. I didn't acquire all those WOW shares at once, but in different chunks at different times. At least 25% of the shareholders of the transferor foreign company remain shareholders of the transferee foreign company; Such transfer is not chargeable to capital gains tax in the country in which the transferor foreign company is incorporated. Suppose you purchased your original Woolworths shares for $30.00 each. The Act also provides that while determining the book value of property, any change in the value of assets consequent to their revaluation needs to be ignored. 85.81% of the total cost bases of your Woolworths Group shares just before the demerger to your Woolworths Group shares, and. A new provision has been introduced in the Act [55] which provides that difference between the consideration and prescribed fair market value [56] of property [57] received by any person is liable to be taxed as income from other sources in the hands of the recipient if they are acquired without consideration or for a consideration that is lower than the aggregate fair market value (provided aggregate fair market value of such propertiesexceeds consideration paid, if any, by more than INR50,000). Woolworths shareholders will be issued Endeavour Group shares which are expected to commence trading on the ASX on Thursday 24 June. olY I Y@G. If you wanted your stapled securities sold in the sale facility, you did not need to do anything. If you owned Woolworths shares on 30 November 2012 but sold them before 11December 2012, follow the instructions under Shares sold before 11December 2012. On EBIT, Endeavours contribution was $693m or 21.5% and on NPAT, 20%. // -->