What this ruling covers
The Australian Taxation Office has issued Class Ruling CR 2026/64 confirming the income tax treatment for ordinary shareholders of Qube Holdings Limited who participated in a scheme of arrangement. Under that scheme, Rubik Australia Pty Limited acquired all Qube Holdings shares on 14 August 2026.
Dividends covered by the ruling
The ruling addresses two dividends paid to Qube Holdings shareholders:
- Interim dividend: a fully franked interim dividend of $0.0535 per share, paid on 9 April 2026.
- Special dividend: a fully franked special dividend of $0.3465 per share, paid on 23 July 2026.
Scope of the ruling
The ruling applies to shareholders who:
- held Qube Holdings shares on capital account,
- were registered on the Qube Share Register on 24 July 2026 at 7:00pm AEST (the Scheme Record Date), and
- acquired their shares on or after 20 September 1985.
The ruling does not apply to temporary residents, tax-exempt entities, employee share scheme participants, or those subject to the financial arrangements rules in Division 230.
The ruling period runs from 1 July 2025 to 30 June 2027.
How dividends and franking credits are treated
Both the interim dividend and the special dividend are assessable income in the income year in which they were paid. For Australian resident shareholders who are a qualified person, the attached franking credits are also assessable income and a corresponding tax offset applies. Special rules under section 207-45 apply to shareholders who held Qube Holdings shares through a trust or partnership, affecting how franking credits flow through to beneficiaries or partners.
Capital gains tax consequences
The ruling also covers the capital gains tax consequences for shareholders who sold their Qube Holdings shares under the scheme of arrangement on 14 August 2026. Those details appear in paragraphs 47 to 83 of the ruling.
Key actions
- Check whether Qube Holdings shares were held on the Scheme Record Date of 24 July 2026 at 7:00pm AEST and whether either or both dividends were received - if yes, this ruling directly affects how those dividends are reported in a tax return.
- Include both the interim dividend ($0.0535 per share) and the special dividend ($0.3465 per share) as assessable income in the income year in which they were paid, and include the attached franking credits as assessable income with a corresponding tax offset if the shareholder is an Australian resident and a qualified person.
- For shares held through a trust or partnership, confirm with a tax adviser how the franking credits flow through to beneficiaries or partners, as special rules apply under section 207-45.
- For shareholders who sold Qube Holdings shares under the scheme of arrangement on 14 August 2026, confirm with a tax adviser whether the capital proceeds are subject to CGT, as the ruling covers those consequences in paragraphs 47 to 83.
- Access the full authorised PDF version of CR 2026/64 at https://www.ato.gov.au/law/view/document?docid=CLR/CR202664/NAT/ATO/00001 for the complete ruling including all scheme details.
This is a plain-English summary for information only, not legal or compliance advice. Always check the official source or consult a qualified professional.