Ann: Chairman's EGM Address, page-29

Dividend and Capital Gains are treated as 2 separate tax events. Dividend is included in your Income Tax and Capitals Gains attracts Capital Gains Tax. They are 2 separate taxes and you will find that one cannot be used to offset the other.

CG can receive a 50% discount if you have held for more that 1yr. This does not apply to dividends. Dividends on the other hand can be franked (company has prepaid some tax for you) or unfranked.

In this case we are getting a bit of both... 25% of the payout is a CGT event - which you will be able to get a 50% discount on if held >12mths, and the remaining 75% is an unfranked dividend which will go onto your income tax (not including of course that you will still hold stock in PSC v2). They company will outline how to calculate your CGT later when they get their ruling from the ATO. Depending on when you bought and how the company/ATO advise on how to calculate the CGT base you may not even have a CG and may either make a CGT gain OR loss.

Foreign holders don't need to pay CGT, and as Dividend is unfranked and likely to be Foreign Conduit Income they will unlikely need to pay tax on the Div either, meaning there is money to be made on the advantageous tax position, which will also hopefully flow on as a benefit to us by holding our share price up.

Hope I'm not teaching you to suck eggs... just trying to answer your question. Obviously you should seek better advice than my rudimentary explanation if this tax stuff isn't quite clear.

Hope that helps.