Legislation

ITAA 1936 s What this Ruling is about 1 Relevant provisions 2 Class of entities 3 Qualifications 4 Date of effect 7 Scheme 8 Background 9 Relevant entities 10 BHP 10 Plc 13 South32 14 BHP Billiton Group 15 Pre-demerger transactions 16 The demerger of South32 17 Subsequent transactions 20 Sale facility 22 The demerger distribution 25 Reasons for the demerger 27 Other matters 28 Ruling 34 CGT consequences 34 Demerger roll-over relief 34 South32 shares received by BHP shareholder that holds Pre-CGT BHP shares 36 South32 shares received by BHP shareholder that holds Post-CGT BHP shares 38 Acquisition date of the South32 shares for the purposes of the CGT discount 40 Dividend consequences 42 Dividend withholding tax 44 Section 45

ATO documents that consider ITAA 1936 s What this Ruling is about 1 Relevant provisions 2 Class of entities 3 Qualifications 4 Date of effect 7 Scheme 8 Background 9 Relevant entities 10 BHP 10 Plc 13 South32 14 BHP Billiton Group 15 Pre-demerger transactions 16 The demerger of South32 17 Subsequent transactions 20 Sale facility 22 The demerger distribution 25 Reasons for the demerger 27 Other matters 28 Ruling 34 CGT consequences 34 Demerger roll-over relief 34 South32 shares received by BHP shareholder that holds Pre-CGT BHP shares 36 South32 shares received by BHP shareholder that holds Post-CGT BHP shares 38 Acquisition date of the South32 shares for the purposes of the CGT discount 40 Dividend consequences 42 Dividend withholding tax 44 Section 45