What this ruling covers
The Australian Taxation Office has issued Class Ruling CR 2026/60, which sets out the tax treatment for shareholders of Qoria Limited who exchanged their Qoria shares for CHESS Depositary Interests (CDIs) in Aura Consolidated Group, Inc. on 17 July 2026 under a scheme of arrangement.
The ruling applies for the 2026-27 income year (1 July 2026 to 30 June 2027).
CGT event and roll-over
The ruling confirms that a CGT event - specifically CGT event A1 - occurred on 17 July 2026 for eligible shareholders.
Eligible shareholders who made a capital gain on that exchange can choose a scrip for scrip roll-over to defer that gain. If the roll-over is chosen, the capital gain is disregarded at the time of the exchange. The cost base of the new Aura CDIs is set based on the original cost base of the Qoria shares.
Who the ruling does not cover
The ruling only covers shareholders who held Qoria shares on capital account. The ruling does not cover:
- traders (shareholders who held Qoria shares on revenue account)
- temporary residents
- shareholders subject to the Division 230 financial arrangement rules
Key actions
- Shareholders who held Qoria shares on the record date of 10 July 2026 and received Aura CDIs on 17 July 2026 are required to confirm with an accountant or tax adviser whether they qualify for the scrip for scrip roll-over under CR 2026/60.
- If the roll-over is chosen, tax records are required to reflect the adjusted cost base of the Aura CDIs (based on the original cost base of the Qoria shares) and the original acquisition date of those Qoria shares - both matter for future CGT calculations.
- If the roll-over is not chosen, the capital gain or loss is calculated based on the market value of the Aura CDIs received on 17 July 2026 compared to the Qoria shares' cost base, and this is included in the 2025-26 or 2026-27 tax return as appropriate.
- Shareholders who are foreign residents, hold shares on revenue account, or are subject to Division 230 rules are required to review the full ruling at https://www.ato.gov.au/law/view/document?docid=CLR/CR202660/NAT/ATO/00001 or speak to a tax adviser, as the roll-over may not be available to them.
This is a plain-English summary for information only, not legal or compliance advice. Always check the official source or consult a qualified professional.