Legislation

ITAA 1936 s What this Ruling is about 1 Relevant provision(s) 2 Class of entities 3 Qualifications 4 Date of effect 7 Scheme 8 The Brambles Group 10 The Demerger 18 Pre-Demerger transactions 28 Reasons for the restructure 31 Accounting for the distribution to effect the Demerger 32 BL Share Rights issued under employee share plans 34 Other matters 36 Ruling 39 CGT consequences 39 CGT event G1 39 Capital gain 40 Demerger roll-over 42 CGT consequences of choosing demerger roll-over 44 CGT consequences of not choosing demerger roll-over 49 Acquisition date of the RHL shares for the purposes of making a discount capital gain 50 Divided consequences 51 Distribution debited to the share capital account is not a dividend for income tax purposes 51 Balance of the distribution is a demerger dividend 52 Application of sections 45B, 45BA and 45C

ATO documents that consider ITAA 1936 s What this Ruling is about 1 Relevant provision(s) 2 Class of entities 3 Qualifications 4 Date of effect 7 Scheme 8 The Brambles Group 10 The Demerger 18 Pre-Demerger transactions 28 Reasons for the restructure 31 Accounting for the distribution to effect the Demerger 32 BL Share Rights issued under employee share plans 34 Other matters 36 Ruling 39 CGT consequences 39 CGT event G1 39 Capital gain 40 Demerger roll-over 42 CGT consequences of choosing demerger roll-over 44 CGT consequences of not choosing demerger roll-over 49 Acquisition date of the RHL shares for the purposes of making a discount capital gain 50 Divided consequences 51 Distribution debited to the share capital account is not a dividend for income tax purposes 51 Balance of the distribution is a demerger dividend 52 Application of sections 45B, 45BA and 45C