Ann: ATO Class Ruling for In-specie Distribution of GMD Shares, page-7

I don't think that is that case. Would be nice to know what your accountant thinks. We shall compare notes when after I talk to mine.

I think this CR 2023/72 ATO ruling is a dogs breakfast. ATO is treating it as CGT event(s) instead of a much simpler Return of capital Dividend or Income. So per SBM share they've ruled that you've made 30.42 cents in gains per SBM share on implementation. Therefore you are liable for CGT gain if your SBM cost base is below 30.42 cents under G1 scenario. If you held SBM shares at the Record Date but disposed of them prior to the Implementation Date you may also be liable for gains under C2 scenario.