Class Ruling CR 2026/10

What this ruling is about: 1. This Ruling sets out the income tax consequences for shareholders of betr Entertainment Limited (BBT) who participated in the off-market selective share buy-back (Buy-Back) of BBT shares approved by shareholders at an extraordinary general meeting on 22 September 2025. 2. Details of this scheme are set out in paragraphs 17 to 38 of this Ruling. 3. All legislative references in this Ruling are to the Income Tax Assessment Act 1997 (ITAA 1997), unless otherwise indicated. Who this Ruling applies to 4. This Ruling applies to you if you: 5. This Ruling does not apply to you if you are subject to the taxation of financial arrangements rules in Division 230 in relation to the scheme outlined in paragraphs 17 to 38 of this Ruling. Note: Division 230 will not apply to individuals unless they have made an election for it to apply. When this Ruling applies 6. This Ruling applies from 1 July 2025 to 30 June 2026. Off-market purchase 7. The Buy-Back is an off-market purchase for the purposes of Division 16K of the ITAA 1936 (section 159GZZZK of the ITAA 1936). No part of the Buy-Back price is a dividend 8. No part of the Buy-Back price you received is taken to be a dividend as BBT is a listed public company (as defined in subsection 995-1(1)) and the Buy-Back is an off-market purchase (section 159GZZZPA of the ITAA 1936). Sale consideration 9. You are taken to have received the Buy-Back price of $0.32 as consideration for each BBT share you sold in the Buy-Back on 20 October 2025 (section 159GZZZQ of the ITAA 1936). 10. The consideration you are taken to have received is not adjusted by subsections 159GZZZQ(2) to (9) of the ITAA 1936. Capital gains tax consequences 11. CGT event A1 happened to you on 20 October 2025 when you disposed of each of your BBT shares to BBT in the Buy-Back (section 104-10). 12. The Buy-Back price of $0.32 per BBT share represents the capital proceeds you received for each BBT share you sold under the Buy-Back (subsection 116-20(1)). 13. If you did not hold your BBT shares through a partnership, you made a: 14. Where you made a capital gain, you will not be able to treat the capital gain as a 'discounted capital gain' as you will not have held your BBT shares for at least 12 months (Subdivision 115-A). 15. If you held the BBT shares through a partnership, any capital gain or capital loss will be made by the partners individually (subsection 106-5(1)). Each partner in a partnership has a separate cost base and reduced cost base for the partner's interest in each BBT share sold in the Buy-Back by the partnership (subsection 106-5(2)). Anti-avoidance provisions 16. The Commissioner will not a make a determination under subsection 45A(2) or 45B(3) of the ITAA 1936 that section 45C of the ITAA 1936 applies to the whole, or any part, of the Buy-Back price you received. 17. The following description of the scheme is based on information provided by the applicant. If the scheme is not carried out as described, this Ruling cannot be relied upon. 18. Other information referenced in paragraphs 19 to 38 of this Ruling is taken from the Buy-Back booklet announced on the Australian Securities Exchange (ASX) on 2 October 2025. betr Entertainment Limited 19. BBT is a public company listed on the ASX. 20. BBT is a pure-play digital wagering operator providing sports and racing betting products and services to online and phone clients in Australia and North America. 21. As at 30 June 2025, BBT had: 22. BBT has not paid any dividends since its incorporation. 23. As at 19 October 2025, BBT's franking accounting balance was $954,505. Off-market takeover 24. On 16 July 2025, BBT issued a bidder's statement in relation to its off-market takeover offer to acquire all the shares in PointsBet Holdings Limited (PBH) it did not already own or control. BBT increased its takeover offer on 18 August 2025. 25. On 27 August 2025, BBT further increased its takeover offer, where PBH shareholders who accepted the takeover offer received 4.375 BBT shares for every 1 PBH share held (Offer). 26. On 26 September 2025, following the close of the Offer, BBT: Off-market share buy-back 27. On 24 July 2025, BBT announced its intention to undertake a selective buy-back following the close of the Offer, subject to relevant shareholder approval. The purpose of the Buy-Back was to increase the attractiveness of the Offer by giving PBH shareholders a partial cash alternative. 28. The Buy-Back did not form part of the Offer terms and conditions and the Offer was not conditional on shareholder approval of the Buy-Back. 29. On 22 September 2025, a resolution in favour of the Buy-Back was agreed to by shareholders at an extraordinary general meeting. 30. The Buy-Back was selective and only offered to specific BBT shareholders who: 31. Participation in the Buy-Back was voluntary. Shareholders who did not participate (or who were ineligible to participate) in the Buy-Back did not receive any property, dividends or distributions. 32. The majority of shareholders who participated in the Buy-Back had an Australian-registered address. Less than 1% of shareholders who participated in the Buy-Back had an overseas address. 33. The Buy-Back opened on 2 October 2025 and closed on 16 October 2025. 34. On 20 October 2025, BBT announced that it had bought back 127,029,704 shares at a fixed price of $0.32 per share, representing approximately 10.88% of total shares on issue. All BBT shares bought back under the Buy-Back were cancelled. 35. On 23 October 2025, participating shareholders received $0.32 per share they sold in the Buy-Back. 36. BBT debited $0.32 per share purchased under the Buy-Back to its share capital account. 37. The Buy-Back was undertaken in accordance with Division 2 of Part 2J.1 of the Corporations Act 2001. Other matters 38. As at 23 October 2025, BBT's 'share capital account' (as defined in section 975-300) was not tainted within the meaning of Division 197. Commissioner of Taxation 1 April 2026 © AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).

Class of entities or scheme: 17. The following description of the scheme is based on information provided by the applicant. If the scheme is not carried out as described, this Ruling cannot be relied upon. 18. Other information referenced in paragraphs 19 to 38 of this Ruling is taken from the Buy-Back booklet announced on the Australian Securities Exchange (ASX) on 2 October 2025. | betr Entertainment Limited: 19. BBT is a public company listed on the ASX. 20. BBT is a pure-play digital wagering operator providing sports and racing betting products and services to online and phone clients in Australia and North America. 21. As at 30 June 2025, BBT had: 22. BBT has not paid any dividends since its incorporation. 23. As at 19 October 2025, BBT's franking accounting balance was $954,505. | Off-market takeover: 24. On 16 July 2025, BBT issued a bidder's statement in relation to its off-market takeover offer to acquire all the shares in PointsBet Holdings Limited (PBH) it did not already own or control. BBT increased its takeover offer on 18 August 2025. 25. On 27 August 2025, BBT further increased its takeover offer, where PBH shareholders who accepted the takeover offer received 4.375 BBT shares for every 1 PBH share held (Offer). 26. On 26 September 2025, following the close of the Offer, BBT: | Off-market share buy-back: 27. On 24 July 2025, BBT announced its intention to undertake a selective buy-back following the close of the Offer, subject to relevant shareholder approval. The purpose of the Buy-Back was to increase the attractiveness of the Offer by giving PBH shareholders a partial cash alternative. 28. The Buy-Back did not form part of the Offer terms and conditions and the Offer was not conditional on shareholder approval of the Buy-Back. 29. On 22 September 2025, a resolution in favour of the Buy-Back was agreed to by shareholders at an extraordinary general meeting. 30. The Buy-Back was selective and only offered to specific BBT shareholders who: 31. Participation in the Buy-Back was voluntary. Shareholders who did not participate (or who were ineligible to participate) in the Buy-Back did not receive any property, dividends or distributions. 32. The majority of shareholders who participated in the Buy-Back had an Australian-registered address. Less than 1% of shareholders who participated in the Buy-Back had an overseas address. 33. The Buy-Back opened on 2 October 2025 and closed on 16 October 2025. 34. On 20 October 2025, BBT announced that it had bought back 127,029,704 shares at a fixed price of $0.32 per share, representing approximately 10.88% of total shares on issue. All BBT shares bought back under the Buy-Back were cancelled. 35. On 23 October 2025, participating shareholders received $0.32 per share they sold in the Buy-Back. 36. BBT debited $0.32 per share purchased under the Buy-Back to its share capital account. 37. The Buy-Back was undertaken in accordance with Division 2 of Part 2J.1 of the Corporations Act 2001. | Other matters: 38. As at 23 October 2025, BBT's 'share capital account' (as defined in section 975-300) was not tainted within the meaning of Division 197. Commissioner of Taxation 1 April 2026 © AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).

Ruling: 1. This Ruling sets out the income tax consequences for shareholders of betr Entertainment Limited (BBT) who participated in the off-market selective share buy-back (Buy-Back) of BBT shares approved by shareholders at an extraordinary general meeting on 22 September 2025. 2. Details of this scheme are set out in paragraphs 17 to 38 of this Ruling. 3. All legislative references in this Ruling are to the Income Tax Assessment Act 1997 (ITAA 1997), unless otherwise indicated. | Who this Ruling applies to: 4. This Ruling applies to you if you: 5. This Ruling does not apply to you if you are subject to the taxation of financial arrangements rules in Division 230 in relation to the scheme outlined in paragraphs 17 to 38 of this Ruling. Note: Division 230 will not apply to individuals unless they have made an election for it to apply. | When this Ruling applies: 6. This Ruling applies from 1 July 2025 to 30 June 2026. | Off-market purchase: 7. The Buy-Back is an off-market purchase for the purposes of Division 16K of the ITAA 1936 (section 159GZZZK of the ITAA 1936). | No part of the Buy-Back price is a dividend: 8. No part of the Buy-Back price you received is taken to be a dividend as BBT is a listed public company (as defined in subsection 995-1(1)) and the Buy-Back is an off-market purchase (section 159GZZZPA of the ITAA 1936). | Sale consideration: 9. You are taken to have received the Buy-Back price of $0.32 as consideration for each BBT share you sold in the Buy-Back on 20 October 2025 (section 159GZZZQ of the ITAA 1936). 10. The consideration you are taken to have received is not adjusted by subsections 159GZZZQ(2) to (9) of the ITAA 1936. | Capital gains tax consequences: 11. CGT event A1 happened to you on 20 October 2025 when you disposed of each of your BBT shares to BBT in the Buy-Back (section 104-10). 12. The Buy-Back price of $0.32 per BBT share represents the capital proceeds you received for each BBT share you sold under the Buy-Back (subsection 116-20(1)). 13. If you did not hold your BBT shares through a partnership, you made a: 14. Where you made a capital gain, you will not be able to treat the capital gain as a 'discounted capital gain' as you will not have held your BBT shares for at least 12 months (Subdivision 115-A). 15. If you held the BBT shares through a partnership, any capital gain or capital loss will be made by the partners individually (subsection 106-5(1)). Each partner in a partnership has a separate cost base and reduced cost base for the partner's interest in each BBT share sold in the Buy-Back by the partnership (subsection 106-5(2)). | Anti-avoidance provisions: 16. The Commissioner will not a make a determination under subsection 45A(2) or 45B(3) of the ITAA 1936 that section 45C of the ITAA 1936 applies to the whole, or any part, of the Buy-Back price you received. 17. The following description of the scheme is based on information provided by the applicant. If the scheme is not carried out as described, this Ruling cannot be relied upon. 18. Other information referenced in paragraphs 19 to 38 of this Ruling is taken from the Buy-Back booklet announced on the Australian Securities Exchange (ASX) on 2 October 2025. | betr Entertainment Limited: 19. BBT is a public company listed on the ASX. 20. BBT is a pure-play digital wagering operator providing sports and racing betting products and services to online and phone clients in Australia and North America. 21. As at 30 June 2025, BBT had: 22. BBT has not paid any dividends since its incorporation. 23. As at 19 October 2025, BBT's franking accounting balance was $954,505. | Off-market takeover: 24. On 16 July 2025, BBT issued a bidder's statement in relation to its off-market takeover offer to acquire all the shares in PointsBet Holdings Limited (PBH) it did not already own or control. BBT increased its takeover offer on 18 August 2025. 25. On 27 August 2025, BBT further increased its takeover offer, where PBH shareholders who accepted the takeover offer received 4.375 BBT shares for every 1 PBH share held (Offer). 26. On 26 September 2025, following the close of the Offer, BBT: | Off-market share buy-back: 27. On 24 July 2025, BBT announced its intention to undertake a selective buy-back following the close of the Offer, subject to relevant shareholder approval. The purpose of the Buy-Back was to increase the attractiveness of the Offer by giving PBH shareholders a partial cash alternative. 28. The Buy-Back did not form part of the Offer terms and conditions and the Offer was not conditional on shareholder approval of the Buy-Back. 29. On 22 September 2025, a resolution in favour of the Buy-Back was agreed to by shareholders at an extraordinary general meeting. 30. The Buy-Back was selective and only offered to specific BBT shareholders who: 31. Participation in the Buy-Back was voluntary. Shareholders who did not participate (or who were ineligible to participate) in the Buy-Back did not receive any property, dividends or distributions. 32. The majority of shareholders who participated in the Buy-Back had an Australian-registered address. Less than 1% of shareholders who participated in the Buy-Back had an overseas address. 33. The Buy-Back opened on 2 October 2025 and closed on 16 October 2025. 34. On 20 October 2025, BBT announced that it had bought back 127,029,704 shares at a fixed price of $0.32 per share, representing approximately 10.88% of total shares on issue. All BBT shares bought back under the Buy-Back were cancelled. 35. On 23 October 2025, participating shareholders received $0.32 per share they sold in the Buy-Back. 36. BBT debited $0.32 per share purchased under the Buy-Back to its share capital account. 37. The Buy-Back was undertaken in accordance with Division 2 of Part 2J.1 of the Corporations Act 2001. | Other matters: 38. As at 23 October 2025, BBT's 'share capital account' (as defined in section 975-300) was not tainted within the meaning of Division 197. Commissioner of Taxation 1 April 2026 © AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).




What this Ruling is about | If this Ruling applies to you, and you correctly rely on it, we will apply the law to you in the way set out in this Ruling. That is, you will not pay any more tax or penalties or interest in respect of the matters covered by this Ruling.


Legislative references: ITAA 1936 6(1) ITAA 1936 45A(2) ITAA 1936 45B(3) ITAA 1936 45C ITAA 1936 Div 16K ITAA 1936 159GZZZK ITAA 1936 159GZZZPA ITAA 1936 159GZZZQ ITAA 1936 159GZZZQ(2) ITAA 1936 159GZZZQ(3) ITAA 1936 159GZZZQ(4) ITAA 1936 159GZZZQ(5) ITAA 1936 159GZZZQ(6) ITAA 1936 159GZZZQ(7) ITAA 1936 159GZZZQ(8) ITAA 1936 159GZZZQ(9) ITAA 1997 104-10 ITAA 1997 104-10(4) ITAA 1997 106-5(1) ITAA 1997 106-5(2) ITAA 1997 Subdiv 115-A ITAA 1997 116-20(1) ITAA 1997 Div 197 ITAA 1997 Div 230 ITAA 1997 975-300 ITAA 1997 977-50 ITAA 1997 995-1(1) Corporations Act 2001 Pt 2J.1 Div 2