Class Ruling CR 2007/45
Date of effect: 30 June 2007

What this ruling is about: 1. This Ruling sets out the Commissioner's opinion on the way in which the relevant provision(s) identified below apply to the defined class of entities, who take part in the scheme to which this Ruling relates. Relevant provision(s) 2. The relevant provisions dealt with in this Ruling are: All subsequent references are to the ITAA 1936 unless otherwise stated. Class of entities 3. The class of entities to which this Ruling applies is the members of IOR Friendly Society Limited (IOR) and employees of the IOR Group who receive shares in IOR Group Limited (IORG) from IORG as a result of the demutualisation of IOR in accordance with the scheme identified in this Ruling. Qualifications 4. The class of entities defined in this Ruling may rely on its contents provided the scheme actually carried out is carried out in accordance with the scheme described in paragraph 11 of this Ruling. 5. If the scheme actually carried out is materially different from the scheme that is described in this Ruling, then: 6. This work is copyright. Apart from any use as permitted under the Copyright Act 1968 , no part may be reproduced by any process without prior written permission from the Commonwealth. Requests and inquiries concerning reproduction and rights should be addressed to:

Class of entities or scheme: 3. The class of entities to which this Ruling applies is the members of IOR Friendly Society Limited (IOR) and employees of the IOR Group who receive shares in IOR Group Limited (IORG) from IORG as a result of the demutualisation of IOR in accordance with the scheme identified in this Ruling. | Qualifications: 4. The class of entities defined in this Ruling may rely on its contents provided the scheme actually carried out is carried out in accordance with the scheme described in paragraph 11 of this Ruling. 5. If the scheme actually carried out is materially different from the scheme that is described in this Ruling, then: 6. This work is copyright. Apart from any use as permitted under the Copyright Act 1968 , no part may be reproduced by any process without prior written permission from the Commonwealth. Requests and inquiries concerning reproduction and rights should be addressed to: 7. This Ruling applies to the income years ended 30 June 2007, 30 June 2008, 30 June 2009 and 30 June 2010. However, the Ruling does not apply to taxpayers to the extent that it conflicts with the terms of settlement of a dispute agreed to before the date of issue of the Ruling. Furthermore, the Ruling only applies to the extent that: 8. If this Ruling is inconsistent with a later public or private ruling, the relevant class of entities may rely on either Ruling which applies to them (item 1 of subsection 357-75(1) of Schedule 1 to the Taxation Administration Act 1953 (TAA)). 9. If this Ruling is inconsistent with an earlier private ruling, the private ruling is taken not to have been made if, when the Ruling is made, the following two conditions are met: 10. If the above two conditions do not apply, the relevant class of entities may rely on either Ruling which applies to them (item 3 of subsection 357-75(1) of Schedule 1 to the TAA). 11. The scheme that is the subject of the Ruling is based on information provided by the applicant. The scheme is based on the following documents. These documents, or relevant parts of them, as the case may be, form part of and are to be read in conjunction with this description. The relevant documents or parts of documents incorporated into this description of the scheme are the: List * means a list referred to in subsection 163(3) of the Corporations Act 2001 which must accompany an application to change from a company limited by guarantee to a company limited by shares, setting out prescribed details about each person to whom shares will be issued on such change of type. 12. The class of entities who receive shares in IORG pursuant to the scheme will be entitled to the tax concessions as provided in Division 9AA of Part III as follows: Note that this Ruling does not apply to shares that are issued under special arrangements which apply to overseas members of IOR and members of IOR who do not confirm their details or otherwise verify their name and address details by the scheme's 'Effective Date'. Commissioner of Taxation 30 May 2007 13. IOR is a 'mutual insurance company' as defined in paragraph 121AB(1)(c) in that it is: 14. Under the scheme, IOR ceases to be a mutual insurance company. The demutualisation will be implemented using a scheme that is reflected by demutualisation method 3, one of the demutualisation methods referred to in section 121AE and set out in section 121AH. The scheme as described satisfies the requirements of section 121AH in that: 15. For the class of entities, the tax consequences set out in this Ruling are given on the basis of the modifications in Table 1 of section 121AS and section 104-35 of the ITAA 1997 as follows: 16. The following is a detailed contents list for this Ruling: Not previously issued as a draft

Ruling: 12. The class of entities who receive shares in IORG pursuant to the scheme will be entitled to the tax concessions as provided in Division 9AA of Part III as follows: Note that this Ruling does not apply to shares that are issued under special arrangements which apply to overseas members of IOR and members of IOR who do not confirm their details or otherwise verify their name and address details by the scheme's 'Effective Date'. Commissioner of Taxation 30 May 2007


Appendix: 13. IOR is a 'mutual insurance company' as defined in paragraph 121AB(1)(c) in that it is: 14. Under the scheme, IOR ceases to be a mutual insurance company. The demutualisation will be implemented using a scheme that is reflected by demutualisation method 3, one of the demutualisation methods referred to in section 121AE and set out in section 121AH. The scheme as described satisfies the requirements of section 121AH in that: 15. For the class of entities, the tax consequences set out in this Ruling are given on the basis of the modifications in Table 1 of section 121AS and section 104-35 of the ITAA 1997 as follows:


What this Ruling is about | NOT LEGALLY BINDING SECTION: | A public ruling is an expression of the Commissioner's opinion about the way in which a relevant provision applies, or would apply, to entities generally or to a class of entities in relation to a particular scheme or a class of schemes. | If you rely on this ruling, we must apply the law to you in the way set out in the ruling (or in a way that is more favourable for you if we are satisfied that the ruling is incorrect and disadvantages you, and we are not prevented from doing so by a time limit imposed by the law). You will be protected from having to pay any underpaid tax, penalty or interest in respect of the matters covered by this ruling if it turns out that it does not correctly state how the relevant provision applies to you. | Appendix 2 - Detailed contents list


Legislative references: ITAA 1936 Pt III Div 9AA ITAA 1936 121AB(1)(c) ITAA 1936 121AD(3) ITAA 1936 121AE ITAA 1936 121AE(4) ITAA 1936 121AE(6) ITAA 1936 121AH ITAA 1936 121AH(1)(a) ITAA 1936 121AH(1)(b) ITAA 1936 121AH(1)(c)(i) ITAA 1936 121AH(1)(d) ITAA 1936 121AM ITAA 1936 121AQ ITAA 1936 121AS ITAA 1997 Pt 3-1 ITAA 1997 104-35 ITAA 1997 104-35(5)(c) ITAA 1997 Pt 3-3 ITAA 1997 995-1(1) TAA 1953 TAA 1953 Sch 1 357-75(1) Corporations Act 2001 163(3) Corporations Act 2001 166(2) Copyright Act 1968
Subject references: banking, finance and securities financial institutions financial services industry friendly societies