Acquisition of Stockland stapled securities

As a securityholder in Stockland, you may have acquired your Stockland stapled securities in one of the following ways:
  • Directly on Australian Stock Exchange Limited (ASX); or
  • Participated in a Dividend Reinvestment Plan (DRP); or
  • Participated in a scrip for scrip takeover; or
  • Participated in the 2 for 5 entitlement equity raising in May 2009 at $2.70 per security; or
  • Participated in the 1988 stapling of Stockland Trust and Stockland Corporation Limited.

Securityholders who have acquired their Stockland stapled securities in one of the above ways and are contemplating selling their Stockland stapled securities will need to calculate the gain/loss on disposal for tax purposes. 

To assist Stockland securityholders in calculating such a gain/loss, the following information is provided. 

If you have acquired your Stockland stapled securities in another way, you should seek your own professional tax advice. 

 

Your investment in Stockland stapled securities

As Stockland is a stapled vehicle, a share in Stockland Corporation Limited (‘SCL’) can only be dealt with on the same terms as a unit in Stockland Trust (‘the Trust’). For capital gains tax purposes, the cost of each Stockland stapled security and the consideration received on disposal of each Stockland stapled security will need to be apportioned between the share in SCL and the unit in the Trust. 

The Australian Tax Office has advised that this apportionment should be done on a reasonable basis. For more information, refer to ‘Stapled securities and capital gains tax’ on the Australian Tax Office website. One possible method of apportionment is on the basis of the relative Net Assets of SCL and the Trust. 

Apportioning the value of your Stockland stapled securities using Net Assets

Securityholders who have acquired their Stockland stapled securities directly (i.e. on the ASX or via the DRP or via the equity raising) and not through a scrip for scrip takeover and propose to sell their Stockland stapled securities will need to apportion both the acquisition price and consideration received on disposal between the share in SCL and the unit in the Trust on a reasonable basis, for example, using the Net Assets of each individual entity, SCL and the Trust. 


To assist securityholders with this apportionment, below is the historical price of Stockland’s stapled securities as well as the Net Assets of SCL and the Trust. 
ASX
The historical daily price of Stockland’s stapled securities covering the period 28 April 1987 to 30 June 2010 can be accessed below. For current information regarding Stockland’s share price, please refer to the ASX website.

The Net Assets for SCL and the Trust are below:

Date Net Assets
SCL Trust
30 June 2017  4.4% 95.6%
31 December 2016 3.9% 96.1%
30 June 2016 2.1% 97.9%
31 December 2015 1.8% 98.2%
30 June 2015 1.5% 98.5%
31 December 2014 1.5% 98.5%
30 June 2014 1.5% 98.5%
31 December 2013* 1.8% 98.2%
30 June 2013 0.0% 100.0%
31 December 2012 0.0% 100.0%
30 June 2012 3.0% 97.0%
31 December 2011 4.0% 96.0%
30 June 2011 4.0% 96.0%
31 December 2010 4.0% 96.0%
30 June 2010 4.0% 96.0%
31 December 2009 3.0% 97.0%
30 June 2009 3.0% 97.0%
31 December 2008 3.0% 97.0%
30 June 2008 6.8% 93.2%
31 December 2007 7.0% 93.0%
30 June 2007 7.0% 93.0%
31 December 2006 7.0% 93.0%
30 June 2006 7.0% 93.0%
31 December 2005 7.0% 93.0%
30 June 2005 8.0% 92.0%
31 December 2004 7.9% 92.1%
30 June 2004 8.0% 92.0%
31 December 2003 8.7% 91.3%
30 June 2003 8.4% 91.6%
31 December 2002 11.1% 88.9%
30 June 2002 11.0% 89.0%
31 December 2001 10.9% 89.1%
30 June 2001 10.6% 89.4%
30 June 2000 16.2% 83.8%
30 June 1999 17.2% 82.8%
30 June 1998 16.5% 83.5%
30 June 1997 16.2% 83.8%
30 June 1996 16.5% 83.5%

*Refer to the commentary above in relation to the 2013 Capital Reallocation.

This table is update every six months following the release of the Stockland Group financial statements.

 

Historical Net Assets for SCL and the Trust

The historical Net Assets for SCL and the Trust for the years prior to 30 June 1996, can be accessed below.


Distribution Reinvestment Plan (DRP) 

The Stockland DRP was reactivated for the 28 February 2014 distribution and the details are provided below:

Issue Date Period End Date DRP Issue Price ($)
 28 February 2017 31 December 2016  4.38 
31 August 2016 30 June 2016 4.85
29 February 2016 31 December 2015 4.04
31 August 2015 30 June 2015 4.15
27 February 2015 31 December 2014 4.33
29 August 2014 30 June 2014 3.92
28 February 2014 31 December 2013 3.64

The historical Stockland DRP security issue price covering the period 31 August 1983 to 30 June 2009, can be accessed below. 

2013 Capital reallocation

Following shareholder approval on 29 October 2013, capital of just over $500m was reallocated from Stockland Trust (“ST”) to Stockland Corporation Ltd (“SCL”) on 29 November 2013. The capital reallocation was effected by way of a capital return of 22 cents on each unit and the application of that amount of 22 cents as additional capital on each share. The capital reallocation of 22 cents per security results in a change in the CGT cost base of each SCL share and ST unit held on 29 November 2013, with the reduction in CGT cost base in the ST unit being equal to the increase in CGT cost base for the SCL share.

Further details in relation to the capital reallocation are available in the Explanatory Statement dated 25 September 2013 here. 

The Australian Taxation Office has published a Class Ruling in relation to the capital reallocation. Please refer to the following link for the ATO Class Ruling http://law.ato.gov.au/atolaw/view.htm?docid=CLR/CR201382/NAT/ATO/00001.

Scrip for scrip takeovers

Stockland acquired the following Trusts by way of scrip for scrip takeover: 
  • Flinders Industrial Property Trust. 
  • Advance Property Fund. 
  • Australian Commercial Property Trust. 
  • AMP Diversified Property Fund.
If you were an original investor in any of these Trusts, and you participated in the scrip for scrip takeover by Stockland, you will need some additional information that will enable you to work out:
  • The capital gain eligible for rollover relief that has arisen as a result of exchanging your original units in the Trusts for units in Stockland Trust. 
  • The capital gain not eligible for rollover relief that has arisen as a result of exchanging your original units in the Trusts for shares in SCL. 
Below are extracts from the various Bidders Statements for each Trust, and where available, tax information published by the Australian Tax Office with respect to the scrip for scrip takeovers.

Flinders Industrial Property Trust
Advance Property Fund
Australian Commercial Property Trust 
AMP Diversified Property Trust


1988 Stapling

On 11 February 1988 it was resolved that all unitholders of Stockland Trust receive an in specie distribution of shares in Stockland Corporation Limited. These shares were valued at 17.5 cents. 

Consequently, unitholders in Stockland Trust also became shareholders in Stockland Corporation Limited. That is from this date, every transaction on the ASX is for an equal number of shares and units.

The Net Asset split as at 11 February 1988 was:
  • Stockland Trust - 85% 
  • Stockland Corporation Limited - 15%

The following additional background information may be of assistance to you: