Demerger Class Ruling CR 2013/23
Brisbane, April 3, 2013 AEST (ABN Newswire) - As part of the demerger of Talon Petroleum Limited (
ASX:TPD) from Texon Petroleum Ltd (ASX:TXN), a ruling was sought from the Australian Taxation Office (ATO) on the taxation implications for shareholders.
The ATO has issued Class Ruling CR 2013/23 (Ruling), in accordance with that application made by Texon.
The Ruling contains details about the taxation treatment applicable to certain Texon shareholders who received Talon ordinary shares pursuant to the scheme of arrangement (Demerger Scheme) between Texon and its shareholders.
A copy of the Ruling is attached. The Ruling and further guidance on its application are available on the ATO website at:
http://law.ato.gov.au/atolaw/view.htm?docid=CLR/CR201323/NAT/ATO/00001
The Ruling means that, among other things, persons who were residents of Australia for income tax purposes on the record date for the Demerger Scheme, namely 6.00pm on 6 March 2013, and who held Texon shares on capital account will be able to choose demerger roll-over relief in relation to the Demerger Scheme for their Texon shares.
Paragraphs 43 - 45 set out a basis for former Texon Shareholders who choose demerger relief to recalculate/calculate the cost basis and reduced cost basis of their Texon and new Talon Shares. In particular, it states that the ATO accepts that a reasonable apportionment of the summed cost base of the Texon shares prior to the demerger is:
- 84% of the summed cost base to the Texon shares; and
- 16% of the summed cost base to Talon shares.
The above does not take into account the individual circumstances of particular former Texon shareholders and does not constitute tax advice. Appropriate professional advice should be sought on the tax implications of the Demerger Scheme based on individual circumstances.
To view, please visit:
http://media.abnnewswire.net/media/en/docs/ASX-TPD-728700.pdf
Contact
Talon Petroleum Limited
T: +61-7-3211-1122
F: +61-7-3211-0133
E: talon.info@talonpetroleum.com.au
WWW: www.talonpetroleum.com.au
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