What the ruling covers
The Australian Taxation Office has issued ruling CR 2026/83, which applies to shareholders of AMCIL Limited, a listed investment company. The ruling applies specifically to shareholders who choose to receive bonus shares instead of cash dividends under AMCIL's Dividend Substitution Share Plan.
The ruling confirms that bonus shares received under this plan are not treated as taxable dividends. It also sets out how to work out the cost base of the bonus shares for capital gains tax (CGT) purposes when the shares are eventually sold.
Who the ruling applies to
This ruling is specific to AMCIL shareholders and has no relevance to businesses unless they or their clients hold AMCIL shares.
Key actions
- If a shareholder or a client holds AMCIL Limited shares and participates in its Dividend Substitution Share Plan, bonus shares received are not taxed as dividends.
- Records of the acquisition date and cost base of original AMCIL shares are required to be kept, since bonus shares inherit a pro rata share of that cost base for future CGT calculations.
- Bookkeepers and accountants with clients holding AMCIL shares are required to apply the apportionment method shown in the ruling's example when calculating cost base on disposal.
- This ruling does not apply if the shareholder is subject to the taxation of financial arrangements rules in Division 230 of the ITAA 1997, or holds shares as revenue assets or trading stock.
Application period
The ruling applies from 1 July 2025 to 30 June 2029.
This is a plain-English summary for information only, not legal or compliance advice. Always check the official source or consult a qualified professional.