Ann: Court Approves Convening of Scheme Meeting, page-59

Looks like my above statement not quite right.

Following example from ATO site says that the payment would be taxable subject to the following methodology based on the RMS price at the time the new shares are issued.

Example 27: Partial scrip for scrip rollover

Gunther owns 100 shares in Windsor Ltd, each with a cost base of $9. He accepts a takeover offer from Regal Ltd, which provides for Gunther to receive one Regal share plus $10 cash for each share in Windsor. Gunther receives 100 shares in Regal and $1,000 cash. Just after Gunther is issued shares in Regal, each share is worth $20.

Gunther receives $10 cash for each of his Windsor shares and so has $1,000 to which a rollover does not apply.

In this case, it is reasonable to allocate a portion of the cost base of the original shares having regard to the proportion that the cash bears to the total proceeds. That is:

A ÷ B × C = D

Where:

A is cash

B is total proceeds (cash and value of shares received)

C is cost base of original share

D is proportion of cost base for which cash was received

Following on from the formula above, Gunther's calculations are:

$1,000 ÷ $3,000 × $900 = $300

Gunther’s capital gain is as follows:

$1,000 (cash) − $300 (cost base) = $700 (capital gain)

Gunther calculates the cost base of each of his Regal shares as follows:

($900 − $300) ÷ 100 = $6