Ann: Transformational Combination of Ramelius & Spartan, page-117

From my Chat GPT accoutant it seems the cash component will be treated as capital gains - with an proportionate cost base ...and cost base of the RMS shares you continue to hold reduced accordingly ....at least that's my read of the AI response below:

In a scheme of arrangement takeover with a cash and scrip component, where the shareholder receives scrip-for-scrip rollover relief on the share portion, the cash component is generally taxed as follows under Australian tax law:1. Capital Gains Tax (CGT) Treatment of the Cash ComponentThe cash portion of the consideration is generally treated as a capital proceeds for the disposal of the original shares.Since scrip-for-scrip rollover relief only applies to the share portion, the cash portion remains subject to CGT.If the cash component exceeds the cost base of the original shares, a capital gain arises on that amount.2. Partial CGT Event and Cost Base ApportionmentIf a portion of the shares is replaced with scrip, the cost base of the original shares must be apportioned between:The new shares received (which get rollover relief), andThe cash consideration (which triggers an immediate CGT event).The capital gain on the cash portion is calculated as:Capital Gain=Cash Received−Apportioned Cost Base\text{Capital Gain} = \text{Cash Received} - \text{Apportioned Cost Base}Capital Gain=Cash Received−Apportioned Cost BaseIf the original shares were held for more than 12 months, the CGT discount (50% for individuals and trusts) may apply.