What this addendum covers
The Australian Taxation Office (ATO) has issued an addendum to Class Ruling CR 2025/2. The original ruling covers the customer equity scheme operated by DBG Global Enterprises Pty Ltd, a pharmacy group arrangement involving redeemable preference shares (RPS).
Changes made by the addendum
The addendum updates several technical details in the original ruling:
- The scheme's relevant start year has changed from 2025 to 2026.
- The scheme's end year has changed from 2030 to 2031.
- Prescribed timeframes and limits on the number of RPS that can be transferred between the Head Office and Group Pharmacies have been removed.
- A sentence about the intended fifth-anniversary redemption date being postponable has been removed.
- Minor wording corrections have been made.
What has not changed
The addendum does not change the general tax treatment established under the original ruling. The changes reflect updates to the terms of the scheme itself rather than a change in the ATO's tax analysis.
Effective date
The addendum applies from 1 July 2026. Tax positions taken in relation to the scheme from that date are to reflect the updated ruling terms.
Where to find the addendum
The full text of CR 2025/2A is available on the ATO legal database: CR 2025/2A - Addendum.
This is a plain-English summary for information only, not legal or compliance advice. Always check the official source or consult a qualified professional.