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APA Group Stapled Security Tax Cost Base Allocation

Tax Information Relating to your APA Group Stapled Security
On 4 January 2007, new units in APT Investment Trust (APTIT) were issued to unitholders of Australian Pipeline Trust (APT). These new units were stapled to the existing APT units to form the stapled group - APA Group - which is listed on the Australian Stock Exchange under the ASX code "APA".

An APA Group stapled security comprises a unit in APT and a unit in APTIT. These units must be traded as one APA Group stapled security on the Australian Stock Exchange. However APT units and APTIT units each comprise separate assets for Australian capital gains tax purposes.

Your cost base for an APA Group stapled security will be equal to what you paid for it together with any incidential costs of acquisition or disposal such as brokerage fees and stamp duty. You will need to calculate separate cost bases for your APT units and your APTIT units having regard to what you paid for your APA Group stapled security. To do this you will need to apportion your costs base for an APA group stapled security across the units held in APT and APTIT. This apportionment must be done on a reasonable basis. The information provided below is designed to assist you in that task.

This net asset information will be updated shortly after announcement of the APA Group Annual and Half Year Financial Results.

Net Assets of APA Group

Cost Base of securities issued under the Distribution Reinvestment Plan (DRP)
Refer to the Distribution Reinvestment Plan for the issue price of securities. In determining the cost base for an APT unit and an APTIT unit you may use the Net Assets split of APA Group from the table above.

Cost Base of securities issued under the Security Purchase Plan (SPP) on 18 March 2010
The Issue Price under the SPP was $3.37 per stapled security. In determining the cost base, on the basis of the net asset split, allocate 75.7% of the Issue Price to an APT unit and 24.3% of the Issue Price to an APTIT unit.

Cost Base of securities issued under the Security Purchase Plan (SPP) on 8 December 2008
The Issue Price under the SPP was $2.5935 per stapled security. In determining the cost base, on the basis of the net asset split, allocate 70.8% of the Issue Price to an APT unit and 29.2% of the Issue Price to an APTIT unit. 

Cost Base of securities issued under the Security Purchase Plan (SPP) on 29 November 2007
The Issue Price under the SPP was $3.5938 per stapled security. In determining the cost base for an APT unit and an APTIT unit the Board of APA allocated 25% of the Issue Price for each new APA stapled security to an APT unit and 75% of the Issue Price to an APTIT unit.

Cost Base of Units Owned at the Time of Stapling on 4 January 2007
Information on the apportionment of your cost base for units held at the time of stapling was previoiusly provided in the letter to security holders dated 20 July 2007.

Cost Base of Units Acquired Subsequent to Initial Stapling
A reasonable method of apportionment of cost base for acquisitions of APA Group stapled securities subsequent to the initial stapling is to split your APA Group stapled security cost base on the basis of an estimate of the relative net assets of APT and APTIT at the time you acquired your units. In order to assist you with this process, the net assets split for APT and APTIT at 30 June 2007 is shown below.

Australian Taxation Office
On 22 June 2011 the ATO issued Class Ruling CR 2011/60 in relation to the interim capital distribution paid by APT on 17 March 2011. The Class Ruling states that the Commissioner will not seek to apply Section 45B of the Income Tax Assessment Act to deem the interim capital return to be a dividend.

While CR 2011/60 is only binding in respect of APT’s 2011 interim distribution, it is currently expected that future capital returns made by APT will be paid in a manner consistent with the circumstances set out in CR 2011/60.”

Further Information
Further information on the tax treatment of stapled securities can be found on the Australian Taxation Office website.

You should not reply on this information as taxation or financial advice as it may not be relevant to your particular circumstances. You should seek independent advice from a qualified person to determine the taxation consequences applicable to your circumstances.