The Fund pays 15% on income not the shareholders.The...

The Fund pays 15% on income not the shareholders.
The shareholders pay no tax on "Income or gains".

Have a really good read , 12 month rules don't apply.

Again seek professional advice.

"Pooled Development Funds and their shareholders receive tax benefits on the income derived from their equity investments.
This is intended to compensate for the higher risk of investing in SMEs.
Pooled Development Funds are taxed at 15% on the income and gains derived from equity investments in Australian SMEs.
Pooled Development Fund shareholders are exempt from tax on the income and gains derived from holding and disposing of Pooled Development Fund shares.
The extent of the above tax benefits depends upon a number of factors. Pooled Development Funds and their shareholders should seek professional tax advice"

http://www.ausindustry.gov.au/VentureCapital/PooledDevelopmentFundPDF/Documents/Fact%20Sheets/PDF%20Dec08.pdf