![]() ![]() The partial repayment of principal of the Loan Notes reflected 5.62% of the outstanding principal on the Loan Note at the Record Date of the distribution ($0.045 / $0.80 = 5.63%). The Securityholder determined that the acquisition cost for their Loan Notes and Shares comprising their DBI Stapled Security was as follows: Loan NoteĭBI subsequently paid a distribution of 4.5 cents per Stapled Security as a partial repayment of principal on the Loan Notes comprising part of the Stapled Securities. face value) of the Loan Notes comprising part of each Stapled Security was $0.80. At the time of acquisition, the amount payable to the Securityholder on maturity date (i.e. Securityholders should obtain their own professional advice, as necessary, in connection with the completion of their tax returns and to meet their own financial situation and needs.Īn Australian resident Securityholder acquired DBI Stapled Securities on-market for $2.40 per Stapled Security. This example sets out the potential income tax implications associated with an Australian Securityholders allocating an acquisition cost to their Loans Notes which is less than the face value of their Loans Notes. Where an Australian resident Securityholder determines that the acquisition cost of their Loan Notes is less than the face value of the Loan Notes owed to the Australian resident Securityholder at the time of acquisition, repayment of Loan Note principal may give rise to a taxable gain (refer to example below).Īdditional information in relation to working out the acquisition cost of Loan Notes and the cost base of Shares acquired on-market and issued under the IPO is available below. Where an Australian resident Securityholder has determined that the acquisition cost of their Loan Notes is equal to the face value of the Loan Notes owed to the Australian resident Securityholder at the time of acquisition, no taxable gain or loss should arise in respect of repayments of Loan Note principal. The extent to which a taxable gain or loss arises for an Australian resident Securityholder on repayment of Loan Note principal should be determined by reference to the acquisition cost allocated to the Loan Note by the Australian resident Securityholder. Accordingly, any taxable gain or loss that may arise on repayment should be determined under section 26BB and 70B of the Income Tax Assessment Act 1936 and treated as a revenue gain or loss. Loan Notes should be considered a “traditional security” for income tax purposes.
0 Comments
Leave a Reply. |
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |