What this ruling covers
The Australian Taxation Office has issued Class Ruling CR 2026/74 confirming the income tax treatment of two return of capital payments made by Senetas Corporation Limited to its shareholders.
The two payments
- First payment: $0.00120772 per share, paid on 27 November 2025
- Second payment: $0.2111 per share, paid on 7 August 2026
Tax treatment confirmed
The ruling confirms that neither payment is treated as a dividend for income tax purposes. Shareholders do not include these amounts in their assessable income as dividends.
Scope of the ruling
The ruling applies to shareholders who held their Senetas shares on capital account - not as trading stock or revenue assets - and were registered on the relevant record dates:
- 20 November 2025 for the first payment
- 31 July 2026 for the second payment
The ruling does not apply to shareholders who are subject to the taxation of financial arrangements rules under Division 230 of the Income Tax Assessment Act 1997.
Key actions
- Shareholders who held Senetas shares on capital account and received either or both payments are required to confirm they do not include these amounts as dividend income in their tax return for the relevant year.
- Shareholders can check whether they were registered on the Senetas share register on 20 November 2025 (for the first payment) or 31 July 2026 (for the second payment) to confirm this ruling applies to them.
- Shareholders subject to Division 230 of the Income Tax Assessment Act 1997 are required to note that this ruling does not apply to them.
- The full ruling is available at https://www.ato.gov.au/law/view/document?docid=CLR/CR202674/NAT/ATO/00001. The ruling also has capital gains tax implications for the cost base of shares held by affected shareholders.
This is a plain-English summary for information only, not legal or compliance advice. Always check the official source or consult a qualified professional.