This is my understanding.
The (initial) SoA offer for each SPR share was 0.6957 RMS shares plus $0.25/SPR share. When offered, the RMS share price was $2.20 and this valued SPR at $1.78 comprising $1.53 (RMS scrip $2.20x0.6957) and $0.25 cash. These ratios may change at the upcoming SoA vote.
The next step is to split the Cost Base of each purchase of SPR shares. Let's say an SPR share was bought for $0.58 (ie one of the CRs):
- Scrip component $0.50 ($0.58 x $1.53/$1.78)
- Cash component $0.08 ($0.58 x $0.25/$1.78)
If the SoA proceeds and the $0.25 cash component is paid, it is a CGT event and tax is payable:
- Capital gain = $0.17 ($0.25 - $0.08)
- the Scrip component may receive CGT Rollover Relief (eg for Australian tax residents)
The Capital Gain on the Cash component ($0.17) is discounted if the share was bought prior to July 2024. The discount is 50% (share held privately) or 1/3rd (share held in Super).
Assuming CGT Rollover Relief, the Cost Base of the Scrip component ($0.50) is used for any future sales of the new RMS shares.
It's tricky and happy to be corrected!
(20min delay)