I get the rate to be ~9.4% gross or 6.58% FF (2.2% BBSW) on $100...

I get the rate to be ~9.4% gross or 6.58% FF (2.2% BBSW) on $100 (or 9.89% Gross on $95)
The risk is the company does not do as well as it hopes over the next year and delays the dividend. This will mean 0% for the year with perhaps the hope for 9.4% the following year.
ELDPA will most likely trade below $95 after the offer as as far as I see if someone apart from Elders wants to pay $95 dollars, then they would probably be bidding $95.01 today.

The return is certainly tempting and there is a pretty good chance you will get the full return by holding. however if are confident ELD will be paying dividends next year, I'd be selling ELDPA, buy ELD after the ex date when they drift down closer to the issue price. I'd say you will make a greater returner the year.