Class Ruling CR 2025/80

What this ruling is about: 1. This Ruling sets out the income tax consequences of IMB Ltd's off-market share buy-back (buy-back) announced on 27 August 2025. 2. Details of this scheme are set out in paragraphs 34 to 65 of this Ruling. 3. All legislative references in this Ruling are to provisions of the Income Tax Assessment Act 1936 or the Income Tax Assessment Act 1997 (as detailed in the table in the Appendix to this Ruling), unless otherwise indicated. Who this Ruling applies to 4. This Ruling applies to you if you held ordinary shares in IMB and you sold some or all of those shares (IMB shares) under the buy-back. 5. This Ruling does not apply to anyone who is subject to the taxation of financial arrangements rules in Division 230 in relation to the scheme outlined in paragraphs 34 to 65 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 as defined by paragraph 159GZZZK(d). Dividend Component and franking credit 8. You are taken to have received a dividend of $1.57 (Dividend Component) for each IMB share that you sold under the buy-back (section 159GZZZP). 9. The Dividend Component is a frankable distribution and is therefore capable of being franked (section 202-40 and section 202-5 respectively). 10. The difference between the buy-back price of $2.74 and the Dividend Component of $1.57 is the Capital Component of $1.17. The Capital Component is not a dividend for income tax purposes (subsection 159GZZZP(2)) Assessability of the Dividend Component Resident shareholders 11. If you are a resident, for each IMB share you sold in the buy-back, you include in your assessable income for the income year ended 30 June 2026: 12. You are entitled to a tax offset equal to the amount of the franking credit on the Dividend Component (subsection 207-20(2)) as long as you are a qualified person. 13. The tax offset is subject to the refundable tax offset rules in Division 67 provided you are not excluded by subsections 67-25(1A) to (1DA). Partnerships 14. If you are a partnership who participated in the buy-back, your assessable income in the income year in which the buy-back occurred for the purposes of calculating the net income of the partnership includes (for each IMB share you sold in the buy-back): Trusts 15. If you are the trustee of a trust who participated in the buy-back, your assessable income in the income year in which the buy-back occurred for the purposes of calculating the net income of the trust includes (for each IMB share you sold in the buy-back): Non-resident shareholders 16. If you are a non-resident who carries on a business at or through a permanent establishment in Australia and the Dividend Component is attributable to the permanent establishment and is not paid to you in your capacity as trustee, you: 17. If you are a non-resident and paragraph 16 of this Ruling does not apply to you, you are not liable for Australian withholding tax on the Dividend Component as it is fully franked (paragraph 128B(3)(ga). Sale Consideration 18. For each IMB share you sold under the buy-back, you are taken to have received or to be entitled to receive $1.17 (Sale Consideration) on 29 October 2025 (section 159GZZZQ). You may be taken to have received a different amount of Sale Consideration if you are a corporate tax entity to which subsections 159GZZZQ(8) and (9) apply. Capital gains tax 19. CGT event A1 happened to you on 29 October 2025 when you disposed of each of your IMB shares in the buy-back (subsection 104-10(1)). 20. The Sale Consideration of $1.17 represents the capital proceeds per IMB share for capital gains tax purposes (Note 3 following subsection 116-20(1)). You may be taken to have received a different amount of Sale Consideration if you are a corporate tax entity to which subsections 159GZZZQ(8) and (9) apply. 21. If you did not hold your IMB shares through a partnership, you made a: 22. Where you made a capital gain, you can treat the capital gain as a discount capital gain if you acquired your IMB shares on or before 29 October 2024 and the other conditions of Subdivision 115-A are met. 23. If you held your IMB 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 IMB share sold in the buy-back by the partnership (subsection 106-5(2)). Shares held as trading stock 24. If you held your IMB shares as 'trading stock' (as defined in subsection 995-1(1)) at the time of the buy-back on 29 October 2025, you: Shares held as revenue assets 25. If you held your IMB shares as 'revenue assets' (as defined in section 977-50), but not as trading stock, you: 26. If you made a capital gain in respect of the IMB shares you held on revenue account but not as trading stock, the capital gain is reduced by the amount that you included in your assessable income (section 118-20). If you made a capital loss, you reduce the reduced cost base by the amount of the allowable deduction (subsection 110-55(9)). Non-resident shareholders  CGT consequences 27. If you were a non-resident shareholder when you sold your IMB shares under the buy-back, you will only have CGT consequences if the shares you sold were 'taxable Australian property' (section 855-10), in which case the consequences as described in paragraphs 18 to 23 of this Ruling will apply to you (subject to paragraph 29 of this Ruling). 28. The share will be taxable Australian property if: 29. A capital gain or capital loss you made from the sale of the IMB share may be proportionately reduced if you used the share in carrying on a business through a permanent establishment for only part of the period from when you acquired the share until CGT event A1 happened because of the sale (section 855-35). Qualified persons 30. You will be a qualified person in relation to the Dividend Component if: 31. The last-in first-out rule in former subsection 160APHI(4) has no effect for the buy-back in respect of any additional IMB shares you acquired after 2 September 2025 which did not confer an entitlement to participate in the buy-back. The anti-avoidance provisions 32. The Commissioner will not make a determination under subsections 45A(2) or 45B(3) that section 45C applies to the whole, or any part, of the Capital Component you received. 33. The Commissioner will not make a determination under paragraph 204-30(3)(c) or paragraph 177EA(5)(b) to deny the whole, or any part, of the imputation benefits you received in relation to the Dividend Component. 34. The following description of the scheme is based on information provided by the applicant. If the scheme including the background is not carried out as described, this Ruling cannot be relied upon. Background Corporate structure 35. IMB is a resident unlisted public company limited by ordinary shares and guarantee. 36. IMB is a mutual authorised deposit-taking institution. 37. IMB is regulated by the Australian Prudential Regulation Authority and the Australian Securities and Investment Commission. 38. IMB trades under the business name 'IMB Bank' following approval from Australian Prudential Regulation Authority to change from a building society to a mutual bank. The change to a mutual bank had no impact on IMB's ownership model, capital structure, balance sheet and capital management program. 39. IMB's assets are largely Australian cash and loan receivables. IMB Members 40. The Members of IMB consist of: A person or entity cannot become a member of IMB solely through shareholding. 41. A person may become a Member of IMB by completing and lodging an application with IMB. Following approval, the person becomes a Member of IMB when their name is entered in the Register of Members. 42. As at 30 June 2025, IMB had approximately 43. The Shareholder Members are a mix of resident individuals, companies, nominee companies, trusts and superannuation funds, and a small number of non-residents. 44. A Shareholder Member is permitted to hold a maximum of 5% of IMB shares. Any excess is forfeited to IMB and the Shareholder Member is appropriately compensated. 45. All IMB shares were acquired after 20 September 1985. 46. IMB disclosed in its 2025 Annual Report that, as at 30 June 2025, it had 24,110,261 fully paid ordinary shares on issue, and had: Share trading 47. IMB operates a trading facility for its shares under Australian Market Licence (IMB Ltd) 2005 and Australian CS Facility Licence (IMB Ltd) 2005 in accordance with the Corporations Act 2001. IMB manually matches buyers and sellers at mutually accepted prices. 48. In holding the licenses mentioned in paragraph 47 of this Ruling, IMB is subject to disclosure obligations, including a requirement to disclose price sensitive information. IMB publishes weekly trading volumes and prices for IMB shares on its website. 49. Approximately 5.6% of all IMB shares were traded during the 12 months to 30 September 2025. The buy-back 50. IMB announced on 27 August 2025 that it would undertake the buy-back of up to a maximum of $7.5 million worth of IMB shares through a tender process. 51. IMB has already completed 6 off-market buy-backs since 2012. 52. On 25 August 2025, the Australian Securities and Investment Commission granted IMB relief to treat the buy-back as an equal access share buy-back in accordance with Division 2 of Part 2J.1 of the Corporations Act 2001. 53. Table 1 of this Ruling outlines the important dates of the buy-back: 54. The tender period for the buy-back commenced on 16 September 2025 and closed on 17 October 2025. During the tender period, eligible Shareholder Members were invited to lodge, withdraw or amend their tenders. 55. All eligible Shareholder Members (except those with Excluded Foreign Shareholding as defined in the IMB Bank Off-Market Buyback Booklet) whose names were on IMB's share register as at close of business 2 September 2025, the Record Date could tender their IMB shares. IMB shares acquired after 2 September 2025, (that is, acquired on or after 3 September 2025  the ex entitlement date) did not confer an entitlement to participate in the buy-back. 56. Participation in the buy-back was voluntary and eligible shareholders who did not wish to participate were not required to take any action and did not receive any property, dividends or distributions as compensation. 57. Shareholder Members were invited to submit offers to sell some or all of their IMB shares at a tender discount between 0% to 5%, inclusive  the Tender Discount Range  and at intervals of 1%, or as a final price tender. The tender discount was applied to the market value of an IMB share (which was worked out as set out in IMB's second undertaking in paragraph 61 of this Ruling).The discount for the buy-back was selected by IMB as 0%. 58. Shareholder Members that held 250 IMB shares or less who wished to participate in the buy-back were required to tender all of their IMB shares at a single tender discount or as a final price tender. 59. For each IMB share that IMB purchased under the buy-back, IMB debited $1.17 of the buy-back price to its share capital account and the balance of the buy-back price to its retained earnings. The Dividend Component was fully franked. 60. IMB was entitled to use a scale-back mechanism in circumstances such as where more IMB shares were tendered than IMB planned to purchase in the buy-back. The scale back would not apply to: 61. IMB made the following undertakings in respect of the buy-back: 62. On 29 October 2025, the Buy-back date, IMB announced that: 63. IMB cancelled all of the IMB shares it purchased under the buy-back. 64. IMB's 'share capital account' (as defined in section 975-300) was not tainted for the purposes of section 197-50. 65. The market value of IMB's assets that are taxable Australian real property do not exceed the sum of the market value of IMB's other assets for the purposes of section 855-30. Commissioner of Taxation 26 November 2025 66. This paragraph sets out the details of the provisions of the Income Tax Assessment Act 1936 or Income Tax Assessment Act 1997 ruled upon or referenced in this Ruling. © 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: 34. The following description of the scheme is based on information provided by the applicant. If the scheme including the background is not carried out as described, this Ruling cannot be relied upon. | Corporate structure: 35. IMB is a resident unlisted public company limited by ordinary shares and guarantee. 36. IMB is a mutual authorised deposit-taking institution. 37. IMB is regulated by the Australian Prudential Regulation Authority and the Australian Securities and Investment Commission. 38. IMB trades under the business name 'IMB Bank' following approval from Australian Prudential Regulation Authority to change from a building society to a mutual bank. The change to a mutual bank had no impact on IMB's ownership model, capital structure, balance sheet and capital management program. 39. IMB's assets are largely Australian cash and loan receivables. | IMB Members: 40. The Members of IMB consist of: A person or entity cannot become a member of IMB solely through shareholding. 41. A person may become a Member of IMB by completing and lodging an application with IMB. Following approval, the person becomes a Member of IMB when their name is entered in the Register of Members. 42. As at 30 June 2025, IMB had approximately 43. The Shareholder Members are a mix of resident individuals, companies, nominee companies, trusts and superannuation funds, and a small number of non-residents. 44. A Shareholder Member is permitted to hold a maximum of 5% of IMB shares. Any excess is forfeited to IMB and the Shareholder Member is appropriately compensated. 45. All IMB shares were acquired after 20 September 1985. 46. IMB disclosed in its 2025 Annual Report that, as at 30 June 2025, it had 24,110,261 fully paid ordinary shares on issue, and had: | Share trading: 47. IMB operates a trading facility for its shares under Australian Market Licence (IMB Ltd) 2005 and Australian CS Facility Licence (IMB Ltd) 2005 in accordance with the Corporations Act 2001. IMB manually matches buyers and sellers at mutually accepted prices. 48. In holding the licenses mentioned in paragraph 47 of this Ruling, IMB is subject to disclosure obligations, including a requirement to disclose price sensitive information. IMB publishes weekly trading volumes and prices for IMB shares on its website. 49. Approximately 5.6% of all IMB shares were traded during the 12 months to 30 September 2025. | The buy-back: 50. IMB announced on 27 August 2025 that it would undertake the buy-back of up to a maximum of $7.5 million worth of IMB shares through a tender process. 51. IMB has already completed 6 off-market buy-backs since 2012. 52. On 25 August 2025, the Australian Securities and Investment Commission granted IMB relief to treat the buy-back as an equal access share buy-back in accordance with Division 2 of Part 2J.1 of the Corporations Act 2001. 53. Table 1 of this Ruling outlines the important dates of the buy-back: 54. The tender period for the buy-back commenced on 16 September 2025 and closed on 17 October 2025. During the tender period, eligible Shareholder Members were invited to lodge, withdraw or amend their tenders. 55. All eligible Shareholder Members (except those with Excluded Foreign Shareholding as defined in the IMB Bank Off-Market Buyback Booklet) whose names were on IMB's share register as at close of business 2 September 2025, the Record Date could tender their IMB shares. IMB shares acquired after 2 September 2025, (that is, acquired on or after 3 September 2025  the ex entitlement date) did not confer an entitlement to participate in the buy-back. 56. Participation in the buy-back was voluntary and eligible shareholders who did not wish to participate were not required to take any action and did not receive any property, dividends or distributions as compensation. 57. Shareholder Members were invited to submit offers to sell some or all of their IMB shares at a tender discount between 0% to 5%, inclusive  the Tender Discount Range  and at intervals of 1%, or as a final price tender. The tender discount was applied to the market value of an IMB share (which was worked out as set out in IMB's second undertaking in paragraph 61 of this Ruling).The discount for the buy-back was selected by IMB as 0%. 58. Shareholder Members that held 250 IMB shares or less who wished to participate in the buy-back were required to tender all of their IMB shares at a single tender discount or as a final price tender. 59. For each IMB share that IMB purchased under the buy-back, IMB debited $1.17 of the buy-back price to its share capital account and the balance of the buy-back price to its retained earnings. The Dividend Component was fully franked. 60. IMB was entitled to use a scale-back mechanism in circumstances such as where more IMB shares were tendered than IMB planned to purchase in the buy-back. The scale back would not apply to: 61. IMB made the following undertakings in respect of the buy-back: 62. On 29 October 2025, the Buy-back date, IMB announced that: 63. IMB cancelled all of the IMB shares it purchased under the buy-back. 64. IMB's 'share capital account' (as defined in section 975-300) was not tainted for the purposes of section 197-50. 65. The market value of IMB's assets that are taxable Australian real property do not exceed the sum of the market value of IMB's other assets for the purposes of section 855-30. Commissioner of Taxation 26 November 2025

Ruling: 1. This Ruling sets out the income tax consequences of IMB Ltd's off-market share buy-back (buy-back) announced on 27 August 2025. 2. Details of this scheme are set out in paragraphs 34 to 65 of this Ruling. 3. All legislative references in this Ruling are to provisions of the Income Tax Assessment Act 1936 or the Income Tax Assessment Act 1997 (as detailed in the table in the Appendix to this Ruling), unless otherwise indicated. | Who this Ruling applies to: 4. This Ruling applies to you if you held ordinary shares in IMB and you sold some or all of those shares (IMB shares) under the buy-back. 5. This Ruling does not apply to anyone who is subject to the taxation of financial arrangements rules in Division 230 in relation to the scheme outlined in paragraphs 34 to 65 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 as defined by paragraph 159GZZZK(d). | Dividend Component and franking credit: 8. You are taken to have received a dividend of $1.57 (Dividend Component) for each IMB share that you sold under the buy-back (section 159GZZZP). 9. The Dividend Component is a frankable distribution and is therefore capable of being franked (section 202-40 and section 202-5 respectively). 10. The difference between the buy-back price of $2.74 and the Dividend Component of $1.57 is the Capital Component of $1.17. The Capital Component is not a dividend for income tax purposes (subsection 159GZZZP(2)) | Resident shareholders: 11. If you are a resident, for each IMB share you sold in the buy-back, you include in your assessable income for the income year ended 30 June 2026: 12. You are entitled to a tax offset equal to the amount of the franking credit on the Dividend Component (subsection 207-20(2)) as long as you are a qualified person. 13. The tax offset is subject to the refundable tax offset rules in Division 67 provided you are not excluded by subsections 67-25(1A) to (1DA). | Partnerships: 14. If you are a partnership who participated in the buy-back, your assessable income in the income year in which the buy-back occurred for the purposes of calculating the net income of the partnership includes (for each IMB share you sold in the buy-back): | Trusts: 15. If you are the trustee of a trust who participated in the buy-back, your assessable income in the income year in which the buy-back occurred for the purposes of calculating the net income of the trust includes (for each IMB share you sold in the buy-back): | Non-resident shareholders: 16. If you are a non-resident who carries on a business at or through a permanent establishment in Australia and the Dividend Component is attributable to the permanent establishment and is not paid to you in your capacity as trustee, you: 17. If you are a non-resident and paragraph 16 of this Ruling does not apply to you, you are not liable for Australian withholding tax on the Dividend Component as it is fully franked (paragraph 128B(3)(ga). | Sale Consideration: 18. For each IMB share you sold under the buy-back, you are taken to have received or to be entitled to receive $1.17 (Sale Consideration) on 29 October 2025 (section 159GZZZQ). You may be taken to have received a different amount of Sale Consideration if you are a corporate tax entity to which subsections 159GZZZQ(8) and (9) apply. | Capital gains tax: 19. CGT event A1 happened to you on 29 October 2025 when you disposed of each of your IMB shares in the buy-back (subsection 104-10(1)). 20. The Sale Consideration of $1.17 represents the capital proceeds per IMB share for capital gains tax purposes (Note 3 following subsection 116-20(1)). You may be taken to have received a different amount of Sale Consideration if you are a corporate tax entity to which subsections 159GZZZQ(8) and (9) apply. 21. If you did not hold your IMB shares through a partnership, you made a: 22. Where you made a capital gain, you can treat the capital gain as a discount capital gain if you acquired your IMB shares on or before 29 October 2024 and the other conditions of Subdivision 115-A are met. 23. If you held your IMB 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 IMB share sold in the buy-back by the partnership (subsection 106-5(2)). | Shares held as trading stock: 24. If you held your IMB shares as 'trading stock' (as defined in subsection 995-1(1)) at the time of the buy-back on 29 October 2025, you: | Shares held as revenue assets: 25. If you held your IMB shares as 'revenue assets' (as defined in section 977-50), but not as trading stock, you: 26. If you made a capital gain in respect of the IMB shares you held on revenue account but not as trading stock, the capital gain is reduced by the amount that you included in your assessable income (section 118-20). If you made a capital loss, you reduce the reduced cost base by the amount of the allowable deduction (subsection 110-55(9)). | Non-resident shareholders  CGT consequences: 27. If you were a non-resident shareholder when you sold your IMB shares under the buy-back, you will only have CGT consequences if the shares you sold were 'taxable Australian property' (section 855-10), in which case the consequences as described in paragraphs 18 to 23 of this Ruling will apply to you (subject to paragraph 29 of this Ruling). 28. The share will be taxable Australian property if: 29. A capital gain or capital loss you made from the sale of the IMB share may be proportionately reduced if you used the share in carrying on a business through a permanent establishment for only part of the period from when you acquired the share until CGT event A1 happened because of the sale (section 855-35). | Qualified persons: 30. You will be a qualified person in relation to the Dividend Component if: 31. The last-in first-out rule in former subsection 160APHI(4) has no effect for the buy-back in respect of any additional IMB shares you acquired after 2 September 2025 which did not confer an entitlement to participate in the buy-back. | The anti-avoidance provisions: 32. The Commissioner will not make a determination under subsections 45A(2) or 45B(3) that section 45C applies to the whole, or any part, of the Capital Component you received. 33. The Commissioner will not make a determination under paragraph 204-30(3)(c) or paragraph 177EA(5)(b) to deny the whole, or any part, of the imputation benefits you received in relation to the Dividend Component. 34. The following description of the scheme is based on information provided by the applicant. If the scheme including the background is not carried out as described, this Ruling cannot be relied upon. | Corporate structure: 35. IMB is a resident unlisted public company limited by ordinary shares and guarantee. 36. IMB is a mutual authorised deposit-taking institution. 37. IMB is regulated by the Australian Prudential Regulation Authority and the Australian Securities and Investment Commission. 38. IMB trades under the business name 'IMB Bank' following approval from Australian Prudential Regulation Authority to change from a building society to a mutual bank. The change to a mutual bank had no impact on IMB's ownership model, capital structure, balance sheet and capital management program. 39. IMB's assets are largely Australian cash and loan receivables. | IMB Members: 40. The Members of IMB consist of: A person or entity cannot become a member of IMB solely through shareholding. 41. A person may become a Member of IMB by completing and lodging an application with IMB. Following approval, the person becomes a Member of IMB when their name is entered in the Register of Members. 42. As at 30 June 2025, IMB had approximately 43. The Shareholder Members are a mix of resident individuals, companies, nominee companies, trusts and superannuation funds, and a small number of non-residents. 44. A Shareholder Member is permitted to hold a maximum of 5% of IMB shares. Any excess is forfeited to IMB and the Shareholder Member is appropriately compensated. 45. All IMB shares were acquired after 20 September 1985. 46. IMB disclosed in its 2025 Annual Report that, as at 30 June 2025, it had 24,110,261 fully paid ordinary shares on issue, and had: | Share trading: 47. IMB operates a trading facility for its shares under Australian Market Licence (IMB Ltd) 2005 and Australian CS Facility Licence (IMB Ltd) 2005 in accordance with the Corporations Act 2001. IMB manually matches buyers and sellers at mutually accepted prices. 48. In holding the licenses mentioned in paragraph 47 of this Ruling, IMB is subject to disclosure obligations, including a requirement to disclose price sensitive information. IMB publishes weekly trading volumes and prices for IMB shares on its website. 49. Approximately 5.6% of all IMB shares were traded during the 12 months to 30 September 2025. | The buy-back: 50. IMB announced on 27 August 2025 that it would undertake the buy-back of up to a maximum of $7.5 million worth of IMB shares through a tender process. 51. IMB has already completed 6 off-market buy-backs since 2012. 52. On 25 August 2025, the Australian Securities and Investment Commission granted IMB relief to treat the buy-back as an equal access share buy-back in accordance with Division 2 of Part 2J.1 of the Corporations Act 2001. 53. Table 1 of this Ruling outlines the important dates of the buy-back: 54. The tender period for the buy-back commenced on 16 September 2025 and closed on 17 October 2025. During the tender period, eligible Shareholder Members were invited to lodge, withdraw or amend their tenders. 55. All eligible Shareholder Members (except those with Excluded Foreign Shareholding as defined in the IMB Bank Off-Market Buyback Booklet) whose names were on IMB's share register as at close of business 2 September 2025, the Record Date could tender their IMB shares. IMB shares acquired after 2 September 2025, (that is, acquired on or after 3 September 2025  the ex entitlement date) did not confer an entitlement to participate in the buy-back. 56. Participation in the buy-back was voluntary and eligible shareholders who did not wish to participate were not required to take any action and did not receive any property, dividends or distributions as compensation. 57. Shareholder Members were invited to submit offers to sell some or all of their IMB shares at a tender discount between 0% to 5%, inclusive  the Tender Discount Range  and at intervals of 1%, or as a final price tender. The tender discount was applied to the market value of an IMB share (which was worked out as set out in IMB's second undertaking in paragraph 61 of this Ruling).The discount for the buy-back was selected by IMB as 0%. 58. Shareholder Members that held 250 IMB shares or less who wished to participate in the buy-back were required to tender all of their IMB shares at a single tender discount or as a final price tender. 59. For each IMB share that IMB purchased under the buy-back, IMB debited $1.17 of the buy-back price to its share capital account and the balance of the buy-back price to its retained earnings. The Dividend Component was fully franked. 60. IMB was entitled to use a scale-back mechanism in circumstances such as where more IMB shares were tendered than IMB planned to purchase in the buy-back. The scale back would not apply to: 61. IMB made the following undertakings in respect of the buy-back: 62. On 29 October 2025, the Buy-back date, IMB announced that: 63. IMB cancelled all of the IMB shares it purchased under the buy-back. 64. IMB's 'share capital account' (as defined in section 975-300) was not tainted for the purposes of section 197-50. 65. The market value of IMB's assets that are taxable Australian real property do not exceed the sum of the market value of IMB's other assets for the purposes of section 855-30. Commissioner of Taxation 26 November 2025 66. This paragraph sets out the details of the provisions of the Income Tax Assessment Act 1936 or Income Tax Assessment Act 1997 ruled upon or referenced in this Ruling. © 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 | Appendix  Legislative provisions | 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. | Division 1A of former Part IIIAA


Related rulings: TD 2004/22 TR 2006/10
Legislative references: Corporations Act 2001 Corporations Act 2001 Pt 2J.1 Div 2
Other references: PS LA 2007/9