Class Ruling CR 2025/75

What this ruling is about: 1. This Ruling sets out the income tax consequences of the special dividend paid by AVJennings Limited (AVJennings) on 6 August 2025 (Special Dividend) and the disposal of all the ordinary shares in AVJennings under a scheme of arrangement implemented on 14 August 2025. 2. Details of this scheme are set out in paragraphs 38 to 69 of this Ruling. 3. All legislative references in this Ruling are to the Income Tax Assessment Act 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: 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. Special Dividend 7. The Special Dividend is a 'dividend' as defined in subsection 6(1) of the ITAA 1936. 8. The Special Dividend is a 'frankable distribution' as defined in section 202-40. Special Dividend, franking credit and tax offset included in the assessable income of Australian-resident shareholders 9. If you are a 'resident of Australia' (as defined in subsection 6(1) of the ITAA 1936), you include the Special Dividend in your assessable income for the income year in which you received the Special Dividend (subparagraph 44(1)(a)(i) of the ITAA 1936). 10. If you are an individual or a 'corporate tax entity' (as defined in section 960-115), the franking credit on the Special Dividend is included in your assessable income and you are entitled to a tax offset equal to the amount of that franking credit (sections 207-20, 207-70 and 207-145) if you: 11. If you are a resident of Australia who received the Special Dividend as a trustee of a trust (the trust not being a complying superannuation entity) or as a partnership, the franking credit on the Special Dividend is included in your assessable income (subsection 207-35(1)) if you are: 12. If you are a resident of Australia who is a partner in a partnership or a beneficiary of a trust, you include your share of the net income of the partnership (under Division 5 of Part III of the ITAA 1936) or the net income of the trust (under Division 6 of Part III of the ITAA 1936) in your assessable income if: In addition, you include your share of the franking credit on the Special Dividend in your assessable income (subsections 207-35(3) and (4) and section 207-37) and you are entitled to a tax offset equal to your share of the franking credit on the Special Dividend (section 207-45). 13. Your entitlement to the franking credit tax offset under Division 207 in relation to the Special Dividend is subject to the refundable tax offset rules (subsection 67-25(1)), unless you are a: Special Dividend paid to non-resident shareholders Special Dividend attributable to a permanent establishment in Australia 14. If you are a non-resident and you received the Special Dividend, and the Special Dividend is attributable to a permanent establishment in Australia (and you did not receive the Special Dividend in your capacity as a trustee): Special Dividend not attributable to a permanent establishment in Australia 15. If you are a non-resident and you received the Special Dividend, and the Special Dividend is not attributable to a permanent establishment in Australia: Qualified person 16. Paragraph 207-145(1)(a) refers to Division 1A of former Part IIIAA of the ITAA 1936, which contains the conditions you must satisfy to be a 'qualified person' in relation to a franked distribution you have received. The main way in which you can be a qualified person is by satisfying the holding period rule in former subsection 160APHO(2) of the ITAA 1936. 17. You will be a qualified person in relation to the Special Dividend by satisfying the holding period rule if, during the period from 15 June 2025 to 10 August 2025 (inclusive), you held each of your AVJennings shares 'at risk' for a continuous period of at least 45 days during which you did not have 'materially diminished risks of loss or opportunities for gain' (as defined in former section 160APHM of the ITAA 1936) in respect of the share. This is because: 18. The small shareholder exception in former section 160APHT of the ITAA 1936 does not apply as the Special Dividend constitutes a 'related payment' for the purposes of former section 160APHN of the ITAA 1936 (former subsection 160APHT(2) of the ITAA 1936). 19. This means that if you are an individual with total franking credit tax offsets of less than $5,000 for the 202526 income year, you must still satisfy the holding period rule in relation to the Special Dividend. Exempting entity and former exempting entity 20. When the Special Dividend was paid to you, AVJennings was not an 'exempting entity' (as defined in section 208-20) or a 'former exempting entity' (as defined in section 208-50). 21. Therefore, section 208-195 will not apply to deny the inclusion in your assessable income of the amount of the franking credit on the Special Dividend you received or deny the franking credit tax offset to which you are otherwise entitled under Division 207. Anti-avoidance and integrity provisions Section 177EA of the ITAA 1936 22. The Commissioner will not make a determination under paragraph 177EA(5)(b) of the ITAA 1936 to deny the whole, or any part, of the imputation benefits you received in relation to the Special Dividend. Section 204-30 23. The Commissioner will not make a determination under paragraph 204-30(3)(c) to deny the whole, or any part, of the imputation benefits you received in relation to the Special Dividend. Dividend stripping operation, distribution washing, foreign income tax deductions 24. Paragraphs 207-145(1)(d), (da) and (db) will not apply to the whole, or any part, of the Special Dividend. Capital gains consequences CGT event A1 happened on the disposal of shares in AVJennings 25. CGT event A1 happened when you disposed of your AVJennings shares to the Bidder under the scheme of arrangement (section 104-10). 26. The time of CGT event A1 was the Scheme Implementation Date of 14 August 2025 (paragraph 104-10(3)(b)). Australian-resident shareholders 27. The capital proceeds you received in respect of CGT event A1 happening to each of your AVJennings shares is $0.488 (subsection 116-20(1)). 28. The capital proceeds do not include the Special Dividend of $0.167 as it was not paid in respect of CGT event A1 happening to your shares in AVJennings. 29. You made a capital gain if the capital proceeds from the disposal of each of your AVJennings share exceeded its cost base (subsection 104-10(4)). The capital gain is the amount of the excess. 30. If you make a capital gain, you can treat the capital gain as a discount capital gain under Subdivision 115-A provided you: 31. If you acquired your AVJennings shares at or before 11:45 am (AEST) on 21 September 1999, you may choose to index your cost base in accordance with Subdivision 960-M up to this time and date for the purposes of calculating your capital gain (Indexation Method). 32. Expenditure incurred after this time and date, or expenditure incurred in relation to AVJennings shares acquired after this time and date, is not eligible to be calculated by using the Indexation Method. 33. You cannot calculate your capital gain from AVJennings shares as a discount capital gain under Subdivision 115-A if you used the Indexation Method at any time in relation to those shares. 34. You made a capital loss if the capital proceeds from the disposal of each of your AVJennings share is less than its reduced cost base (subsection 104-10(4)). The capital loss is the amount of the difference. Foreign resident shareholders 35. If you were a 'foreign resident' or the trustee of a 'foreign trust for CGT purposes' (as defined in subsection 995-1(1)) just before the Scheme Implementation Date, any capital gain or capital loss you made as a result of CGT event A1 happening to your AVJennings shares is disregarded under subsection 855-10(1) if your AVJennings shares were not 'taxable Australian property' (as defined in section 855-15). 36. Your AVJennings shares were taxable Australian property if they were either: 37. Your AVJennings shares were an indirect Australian real property interest if they passed the: 38. 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. AVJennings Limited 39. AVJennings is a company incorporated in Australia. 40. AVJennings operates a business consisting of the development and sale of residential property in Australia and New Zealand. 41. AVJennings' ordinary shares were listed on the Australian Securities Exchange (ASX) and the Singapore Exchange (SGX) through the SGX GlobalQuote platform. 42. AVJennings was the head company of an income tax consolidated group under Part 3-90 before the scheme of arrangement. 43. As of 31 December 2024, AVJennings had: 44. As of 5 May 2025, AVJennings' 3 largest shareholders beneficially held 65.5% of its ordinary shares, with a company incorporated in Singapore holding 54.02%. PM Nominees C Pty Ltd 45. The AVID group is a privately held residential developer in Australia. The group consists of Malone Holdings (Bidder Cayman HoldCo), an entity incorporated in the Cayman Islands, its sibling entities (Project Malone Trust and Project Malone BV) and their subsidiaries. 46. On 22 August 2022, PM Nominees C Pty Ltd (Bidder) was incorporated in Australia for the purpose of acquiring property development platforms. 47. PM Nominees B Pty Ltd (Bidder HoldCo) is a company incorporated in Australia that owns all of the shares in the Bidder. 48. PM Nominees A Pty Ltd (Bidder FinCo) is a company incorporated in Australia that owns all of the shares in Bidder HoldCo. 49. Bidder Cayman HoldCo owns all of the shares in Bidder FinCo. 50. The AVID group is owned by a number of international institutional investors and managed by a specialist global real estate investment manager.

Class of entities or scheme: 51. On 31 March 2025, AVJennings entered into a Scheme Implementation Deed with the Bidder. Under the Deed, AVJennings agreed to propose that AVJennings and its shareholders enter into a scheme of arrangement under Part 5.1 of the Corporations Act 2001 (Corporations Act) pursuant to which the Bidder would acquire all of the ordinary shares in AVJennings. 52. At a shareholder meeting held on 11 July 2025, a resolution in favour of the scheme of arrangement was passed by the shareholders of AVJennings as required by subparagraph 411(4)(a)(ii) of the Corporations Act. 53. On 23 July 2025, the scheme of arrangement was approved by the Supreme Court of New South Wales under paragraph 411(4)(b) of the Corporations Act. 54. AVJennings shares were suspended from trading on the ASX at the close of trading on 24 July 2025. 55. On the Scheme Implementation Date (14 August 2025), the Bidder acquired all of the shares in AVJennings. 56. Under the scheme of arrangement, each AVJennings shareholder as at the Scheme Record Date (11 August 2025) received the Scheme Consideration for each share in AVJennings on the Scheme Implementation Date. 57. The Scheme Consideration was $0.655 per AVJennings share, reduced by the amount of the Special Dividend paid by AVJennings. 58. AVJennings was removed from the official list of the ASX and SGX on 15 August 2025. | Special Dividend: 59. Clause 4.6 of the Scheme Implementation Deed stated that AVJennings may (in its absolute discretion) announce, declare and pay a Special Dividend of up to $0.167 per AVJennings share (Special Dividend). The amount of any Special Dividend (if declared and paid prior to implementation) was to be subtracted from the Scheme Consideration. 60. On 21 July 2025, the directors of AVJennings declared the Special Dividend of $0.167 in respect of each share. The Special Dividend was fully franked. 61. AVJennings shareholders who held their shares on the Special Dividend Record Date (29 July 2025) were paid the Special Dividend on the Special Dividend Payment Date (6 August 2025). 62. The Special Dividend was debited against AVJennings' retained earnings account. 63. The Special Dividend was funded by AVJennings' existing cash reserves generated from its business since 1 April 2025 as retained cash in a company bank account, without any support by the Bidder. AVJennings did not draw down on any debt facility to fund the Special Dividend. 64. AVJennings had sufficient franking credits to fully frank the Special Dividend. 65. The scheme of arrangement was not contingent on the payment of the Special Dividend. 66. No third party (including the Bidder or any of the Bidder's related parties) financed or facilitated the payment of the Special Dividend in any way. 67. No third party (including the Bidder or any of the Bidder's related parties) had any influence or control over the declaration and payment of the Special Dividend. | Other matters: 68. The following facts are relevant for the purposes of section 207-159: | Key dates: 69. The following table is a summary of the key dates for the scheme of arrangement and the Special Dividend: Commissioner of Taxation 22 October 2025 © 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 of the special dividend paid by AVJennings Limited (AVJennings) on 6 August 2025 (Special Dividend) and the disposal of all the ordinary shares in AVJennings under a scheme of arrangement implemented on 14 August 2025. 2. Details of this scheme are set out in paragraphs 38 to 69 of this Ruling. 3. All legislative references in this Ruling are to the Income Tax Assessment Act 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: 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. | Special Dividend: 7. The Special Dividend is a 'dividend' as defined in subsection 6(1) of the ITAA 1936. 8. The Special Dividend is a 'frankable distribution' as defined in section 202-40. | Special Dividend, franking credit and tax offset included in the assessable income of Australian-resident shareholders: 9. If you are a 'resident of Australia' (as defined in subsection 6(1) of the ITAA 1936), you include the Special Dividend in your assessable income for the income year in which you received the Special Dividend (subparagraph 44(1)(a)(i) of the ITAA 1936). 10. If you are an individual or a 'corporate tax entity' (as defined in section 960-115), the franking credit on the Special Dividend is included in your assessable income and you are entitled to a tax offset equal to the amount of that franking credit (sections 207-20, 207-70 and 207-145) if you: 11. If you are a resident of Australia who received the Special Dividend as a trustee of a trust (the trust not being a complying superannuation entity) or as a partnership, the franking credit on the Special Dividend is included in your assessable income (subsection 207-35(1)) if you are: 12. If you are a resident of Australia who is a partner in a partnership or a beneficiary of a trust, you include your share of the net income of the partnership (under Division 5 of Part III of the ITAA 1936) or the net income of the trust (under Division 6 of Part III of the ITAA 1936) in your assessable income if: In addition, you include your share of the franking credit on the Special Dividend in your assessable income (subsections 207-35(3) and (4) and section 207-37) and you are entitled to a tax offset equal to your share of the franking credit on the Special Dividend (section 207-45). 13. Your entitlement to the franking credit tax offset under Division 207 in relation to the Special Dividend is subject to the refundable tax offset rules (subsection 67-25(1)), unless you are a: | Special Dividend attributable to a permanent establishment in Australia: 14. If you are a non-resident and you received the Special Dividend, and the Special Dividend is attributable to a permanent establishment in Australia (and you did not receive the Special Dividend in your capacity as a trustee): | Special Dividend not attributable to a permanent establishment in Australia: 15. If you are a non-resident and you received the Special Dividend, and the Special Dividend is not attributable to a permanent establishment in Australia: | Qualified person: 16. Paragraph 207-145(1)(a) refers to Division 1A of former Part IIIAA of the ITAA 1936, which contains the conditions you must satisfy to be a 'qualified person' in relation to a franked distribution you have received. The main way in which you can be a qualified person is by satisfying the holding period rule in former subsection 160APHO(2) of the ITAA 1936. 17. You will be a qualified person in relation to the Special Dividend by satisfying the holding period rule if, during the period from 15 June 2025 to 10 August 2025 (inclusive), you held each of your AVJennings shares 'at risk' for a continuous period of at least 45 days during which you did not have 'materially diminished risks of loss or opportunities for gain' (as defined in former section 160APHM of the ITAA 1936) in respect of the share. This is because: 18. The small shareholder exception in former section 160APHT of the ITAA 1936 does not apply as the Special Dividend constitutes a 'related payment' for the purposes of former section 160APHN of the ITAA 1936 (former subsection 160APHT(2) of the ITAA 1936). 19. This means that if you are an individual with total franking credit tax offsets of less than $5,000 for the 202526 income year, you must still satisfy the holding period rule in relation to the Special Dividend. | Exempting entity and former exempting entity: 20. When the Special Dividend was paid to you, AVJennings was not an 'exempting entity' (as defined in section 208-20) or a 'former exempting entity' (as defined in section 208-50). 21. Therefore, section 208-195 will not apply to deny the inclusion in your assessable income of the amount of the franking credit on the Special Dividend you received or deny the franking credit tax offset to which you are otherwise entitled under Division 207. | Section 177EA of the ITAA 1936: 22. The Commissioner will not make a determination under paragraph 177EA(5)(b) of the ITAA 1936 to deny the whole, or any part, of the imputation benefits you received in relation to the Special Dividend. | Section 204-30: 23. The Commissioner will not make a determination under paragraph 204-30(3)(c) to deny the whole, or any part, of the imputation benefits you received in relation to the Special Dividend. | Dividend stripping operation, distribution washing, foreign income tax deductions: 24. Paragraphs 207-145(1)(d), (da) and (db) will not apply to the whole, or any part, of the Special Dividend. | CGT event A1 happened on the disposal of shares in AVJennings: 25. CGT event A1 happened when you disposed of your AVJennings shares to the Bidder under the scheme of arrangement (section 104-10). 26. The time of CGT event A1 was the Scheme Implementation Date of 14 August 2025 (paragraph 104-10(3)(b)). | Australian-resident shareholders: 27. The capital proceeds you received in respect of CGT event A1 happening to each of your AVJennings shares is $0.488 (subsection 116-20(1)). 28. The capital proceeds do not include the Special Dividend of $0.167 as it was not paid in respect of CGT event A1 happening to your shares in AVJennings. 29. You made a capital gain if the capital proceeds from the disposal of each of your AVJennings share exceeded its cost base (subsection 104-10(4)). The capital gain is the amount of the excess. 30. If you make a capital gain, you can treat the capital gain as a discount capital gain under Subdivision 115-A provided you: 31. If you acquired your AVJennings shares at or before 11:45 am (AEST) on 21 September 1999, you may choose to index your cost base in accordance with Subdivision 960-M up to this time and date for the purposes of calculating your capital gain (Indexation Method). 32. Expenditure incurred after this time and date, or expenditure incurred in relation to AVJennings shares acquired after this time and date, is not eligible to be calculated by using the Indexation Method. 33. You cannot calculate your capital gain from AVJennings shares as a discount capital gain under Subdivision 115-A if you used the Indexation Method at any time in relation to those shares. 34. You made a capital loss if the capital proceeds from the disposal of each of your AVJennings share is less than its reduced cost base (subsection 104-10(4)). The capital loss is the amount of the difference. | Foreign resident shareholders: 35. If you were a 'foreign resident' or the trustee of a 'foreign trust for CGT purposes' (as defined in subsection 995-1(1)) just before the Scheme Implementation Date, any capital gain or capital loss you made as a result of CGT event A1 happening to your AVJennings shares is disregarded under subsection 855-10(1) if your AVJennings shares were not 'taxable Australian property' (as defined in section 855-15). 36. Your AVJennings shares were taxable Australian property if they were either: 37. Your AVJennings shares were an indirect Australian real property interest if they passed the: 38. 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. | AVJennings Limited: 39. AVJennings is a company incorporated in Australia. 40. AVJennings operates a business consisting of the development and sale of residential property in Australia and New Zealand. 41. AVJennings' ordinary shares were listed on the Australian Securities Exchange (ASX) and the Singapore Exchange (SGX) through the SGX GlobalQuote platform. 42. AVJennings was the head company of an income tax consolidated group under Part 3-90 before the scheme of arrangement. 43. As of 31 December 2024, AVJennings had: 44. As of 5 May 2025, AVJennings' 3 largest shareholders beneficially held 65.5% of its ordinary shares, with a company incorporated in Singapore holding 54.02%. | PM Nominees C Pty Ltd: 45. The AVID group is a privately held residential developer in Australia. The group consists of Malone Holdings (Bidder Cayman HoldCo), an entity incorporated in the Cayman Islands, its sibling entities (Project Malone Trust and Project Malone BV) and their subsidiaries. 46. On 22 August 2022, PM Nominees C Pty Ltd (Bidder) was incorporated in Australia for the purpose of acquiring property development platforms. 47. PM Nominees B Pty Ltd (Bidder HoldCo) is a company incorporated in Australia that owns all of the shares in the Bidder. 48. PM Nominees A Pty Ltd (Bidder FinCo) is a company incorporated in Australia that owns all of the shares in Bidder HoldCo. 49. Bidder Cayman HoldCo owns all of the shares in Bidder FinCo. 50. The AVID group is owned by a number of international institutional investors and managed by a specialist global real estate investment manager. | Scheme of arrangement: 51. On 31 March 2025, AVJennings entered into a Scheme Implementation Deed with the Bidder. Under the Deed, AVJennings agreed to propose that AVJennings and its shareholders enter into a scheme of arrangement under Part 5.1 of the Corporations Act 2001 (Corporations Act) pursuant to which the Bidder would acquire all of the ordinary shares in AVJennings. 52. At a shareholder meeting held on 11 July 2025, a resolution in favour of the scheme of arrangement was passed by the shareholders of AVJennings as required by subparagraph 411(4)(a)(ii) of the Corporations Act. 53. On 23 July 2025, the scheme of arrangement was approved by the Supreme Court of New South Wales under paragraph 411(4)(b) of the Corporations Act. 54. AVJennings shares were suspended from trading on the ASX at the close of trading on 24 July 2025. 55. On the Scheme Implementation Date (14 August 2025), the Bidder acquired all of the shares in AVJennings. 56. Under the scheme of arrangement, each AVJennings shareholder as at the Scheme Record Date (11 August 2025) received the Scheme Consideration for each share in AVJennings on the Scheme Implementation Date. 57. The Scheme Consideration was $0.655 per AVJennings share, reduced by the amount of the Special Dividend paid by AVJennings. 58. AVJennings was removed from the official list of the ASX and SGX on 15 August 2025. | Special Dividend: 59. Clause 4.6 of the Scheme Implementation Deed stated that AVJennings may (in its absolute discretion) announce, declare and pay a Special Dividend of up to $0.167 per AVJennings share (Special Dividend). The amount of any Special Dividend (if declared and paid prior to implementation) was to be subtracted from the Scheme Consideration. 60. On 21 July 2025, the directors of AVJennings declared the Special Dividend of $0.167 in respect of each share. The Special Dividend was fully franked. 61. AVJennings shareholders who held their shares on the Special Dividend Record Date (29 July 2025) were paid the Special Dividend on the Special Dividend Payment Date (6 August 2025). 62. The Special Dividend was debited against AVJennings' retained earnings account. 63. The Special Dividend was funded by AVJennings' existing cash reserves generated from its business since 1 April 2025 as retained cash in a company bank account, without any support by the Bidder. AVJennings did not draw down on any debt facility to fund the Special Dividend. 64. AVJennings had sufficient franking credits to fully frank the Special Dividend. 65. The scheme of arrangement was not contingent on the payment of the Special Dividend. 66. No third party (including the Bidder or any of the Bidder's related parties) financed or facilitated the payment of the Special Dividend in any way. 67. No third party (including the Bidder or any of the Bidder's related parties) had any influence or control over the declaration and payment of the Special Dividend. | Other matters: 68. The following facts are relevant for the purposes of section 207-159: | Key dates: 69. The following table is a summary of the key dates for the scheme of arrangement and the Special Dividend: Commissioner of Taxation 22 October 2025 © 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. | Scheme Implementation Deed executed | First court hearing and release of scheme booklet | Scheme meeting voting record date | Scheme meeting and Extraordinary General Meeting | Special Dividend declared | Special Dividend ex dividend date | Delisting from ASX and termination of quotation on SGX GlobalQuote


Legislative references: ITAA 1936 6(1) ITAA 1936 44(1)(a)(i) ITAA 1936 44(1)(c) ITAA 1936 Part III Div 5 ITAA 1936 Part III Div 6 ITAA 1936 98 ITAA 1936 99A ITAA 1936 128B(3)(ga) ITAA 1936 128B(3E) ITAA 1936 128D ITAA 1936 former Pt IIIAA Div 1A ITAA 1936 former 160APHD ITAA 1936 former 160APHE(1) ITAA 1936 former 160APHM ITAA 1936 former 160APHN ITAA 1936 former 160APHO(1)(b) ITAA 1936 former 160APHO(2) ITAA 1936 former 160APHO(3) ITAA 1936 former 160APHT ITAA 1936 former 160APHT(2) ITAA 1936 former 160APHU(1) ITAA 1936 177EA ITAA 1936 177EA(5)(b) ITAA 1997 67-25(1) ITAA 1997 67-25(1A) ITAA 1997 67-25(1B) ITAA 1997 67-25(1C) ITAA 1997 67-25(1D) ITAA 1997 67-25(1DA) ITAA 1997 83A-10(2) ITAA 1997 104-10 ITAA 1997 104-10(3)(b) ITAA 1997 104-10(4) ITAA 1997 104-165(3) ITAA 1997 Subdiv 115-A ITAA 1997 115-10 ITAA 1997 115-25(1) ITAA 1997 116-20(1) ITAA 1997 202-40 ITAA 1997 204-30 ITAA 1997 204-30(3)(c) ITAA 1997 Div 207 ITAA 1997 207-20 ITAA 1997 207-35(1) ITAA 1997 207-35(3) ITAA 1997 207-35(4) ITAA 1997 207-37 ITAA 1997 207-45 ITAA 1997 207-70 ITAA 1997 207-75 ITAA 1997 207-75(2) ITAA 1997 207-145 ITAA 1997 207-145(1)(a) ITAA 1997 207-145(1)(d) ITAA 1997 207-145(1)(da) ITAA 1997 207-145(1)(db) ITAA 1997 207-159 ITAA 1997 208-20 ITAA 1997 208-50 ITAA 1997 208-195 ITAA 1997 Div 230 ITAA 1997 Subdiv 842-I ITAA 1997 855-10(1) ITAA 1997 855-15 ITAA 1997 855-20 ITAA 1997 855-30 ITAA 1997 855-35 ITAA 1997 Subdiv 960-D ITAA 1997 Subdiv 960-M ITAA 1997 960-115 ITAA 1997 960-195 ITAA 1997 977-50 ITAA 1997 995-1(1) Corporations Act 2001 Pt 5.1 Corporations Act 2001 411(4)(a)(ii) Corporations Act 2001 411(4)(b)