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Jeff16(Initiate)Initiate
20 Jan 2025

A significant quantity of CSR shares held by me as at Scheme of Arrangement date 9/7/24 were previously Pioneer Sugar shares when taken over by CSR. This quantity of Pioneer Sugar shares were acquired by me prior to introduction of CGT 20/9/85. I do also have subsequent shares received under Dividend Reinvestment Plan since 20/9/85.

My question:

Are my previously owned Pioneer Sugar shares acquired by CSR prior to 20/9/85 exempt from CGT?

I am aware that DRP shares issued by CSR since 20/9/85 will be subject to CGT at discount rate of 50%.

Many thanks for your feedback.

2,541 views
4 replies
2,541 views
4 replies

All replies

AriATO(Community Support)Community Support
7 Feb 2025

Hi @Jeff16


Yes, any shares or assets acquired before 20 September 1985 are not subject to CGT. ASX and Delisted records on Pioneer Sugar Mills showed delisting date was on 19/08/1987. Accordingly, any Pioneer share purchased before 20 September 1985 is exempt from CGT. Pioneer shares purchased after 20 September 1985 are subject to CGT. The capital gain on CSR share acquired under the DRP qualified for a 50% discount if the CGT discount rules are complied with.


When CSR was taken over on 9 July 2024, the capital proceeds was $8.88 per share. A fully franked Permitted Dividend was of $0.12 was paid on Monday, 1 July 2024 on shares held on Permitted Dividend Record Date of 24 June 2024. 


Under TR 2010/4, Income tax: capital gains: when a dividend will be included in the capital proceeds from a disposal of shares that happens under a contract or a scheme of arrangement, a dividend paid as part of the scheme is included in capital proceeds if the dividend falls under paragraphs 10 and 11. The Scheme booklet issued on 26 April 2024 states that the acquirer Saint-Gobain, will not be funding the CSR Permitted Dividend. The Permitted Dividend will be funded by CSR from existing cash reserves of CSR, or by CSR drawing down on existing debt facilities and not from an equity raising. Accordingly, the Permitted Divided of $0.12 is assessable income rather than part of capital proceeds. You are entitled to the franking credit attached to the Permitted Dividend if the CSR shares were purchased before Wednesday 8 May 2024


Any CSR share purchased after Wednesday 8 May 2024 will not qualified for franking credits entitlement under the holding period integrity measures as the shares were not held ‘at risk’ for at least 45 days (90 days for preference shares) not counting the day of acquisition or disposal.



Shamus88(I'm new)Registered Tax Professional
5 Sept 2025

Thanks Ari. A question reCGT:

A house sale for CGT is reported in the year of the sale contract date. Here, the scheme of arrangement became legally effective on 19 June 2024. Should an any capital gain on the sale be reported in the 2024 year's return or in the year when the date the scheme is implemented occurs, being 2 July 2024; i.e. in the 2025 return ?

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CSR - Acquisition by Compagnie de Saint-Gobain - Scheme of Arrangement 9 July 2024 | ATO Community