Hi Csnody - I’m not an accountant or a tax expert, so this is my understanding but please don’t take as ‘fact’!
As a stapled trust, APD will distribute its earnings as interest, foreign income capital gains >12months, capital gains <12months, interest etc. The holders of APD then have to pay tax at their assessable rate. The key benefit I see of this is 1/ that capital gains tax will be lower for gains > 12 months when not grouped as ‘income’ and 2/ investors who currently receive a franking credit refund (but won’t if Shortens/Labor changes come thru) will be better off (ie. get the same $’s in hand as currently).
Not sure, but downside I’d guess would be some legal costs to change the structure and possibly some minor additional compliance costs with the stapled structure.
Perhaps others could comment/add/correct?