Following completion of the sale of Main Event, Ardent Leisure Group Limited paid to its shareholders a Return of Capital of 46.0699 cents per share and a Special Dividend of 48.9301 per share on 13 July 2022.
The Australian Taxation Office issued a class ruling regarding the income tax treatment for applicable shareholders of the Group.
A copy of the Class Ruling CR 2022/68 – Ardent Leisure Group Limited – return of capital and special dividend is available here.
On 24 December 2018 (Implementation Date), Ardent Leisure Group (then a Stapled Group comprising Ardent Leisure Limited and Ardent Leisure Management Limited as Responsible Entity for Ardent Leisure Trust) implemented a destapling and corporatisation transaction pursuant to which a new entity, Ardent Leisure Group Limited (ACN 628 881 603) (ALG) acquired all of the shares in Ardent Leisure Limited and all of the units in the Ardent Leisure Trust.
ALG commenced trading on the Australian Securities Exchange (ASX) on a deferred settlement basis on 30 November 2018 and then on a normal T+2 settlement basis on 27 December 2018 under the ticker code ‘ALG’.
On the Implementation Date, and after accounting for the share consolidation which occurred on the Implementation Date, eligible securityholders received one share in ALG in exchange for each stapled security previously held in Ardent Leisure Group (ASX:AAD).
AAD stapled securities ceased trading on the ASX on 29 November 2018 and AAD was removed from the Official List of ASX Limited on 31 December 2018.
Annual Tax Statements
Following the above destapling and corporatisation, Ardent Leisure Group Limited became the sole unit holder of Ardent Leisure Trust. As shareholders of Ardent Leisure Group Limited no longer hold units in Ardent Leisure Trust, they will no longer receive an Annual Tax Statement.
ATO Class Ruling
The Australian Taxation Office issued a class ruling regarding the income tax treatment for applicable securityholders of the Ardent Leisure Group corporatisation proposal.
A copy of the Class Ruling CR 2019/15 – Income Tax: Ardent Leisure Group – Restructure is available here.
The information contained below is historical information relating to stapled structure of Ardent Leisure Group (AAD) prior to December 2018.
Capital Reallocation in December 2014
On 1 December 2014, the Group reallocated capital from Ardent Leisure Trust (ALT) to Ardent Leisure Limited (ALL). This was achieved by a return of capital from ALT to all Securityholders of $0.28 per ALT unit. The return of Trust capital was compulsorily applied on behalf of each Securityholder as a further capital contribution to existing shares in ALL of $0.28 per ALL share.
A summary and examples of the possible tax implications for investors following the capital reallocation on 1 December 2014 can be found in this document.
Allocation of Cost Base
Prior to December 2018, an Ardent Leisure Group (Ardent Leisure) stapled security comprised one unit in Ardent Leisure Trust (“Trust” or “ALT”), stapled to one share in Ardent Leisure Limited (“Company” or “ALL”). For CGT purposes, the unit in ALT and the share in ALL are two separate assets.
If you disposed of your Ardent Leisure investment, you needed to do separate CGT calculations for each of your investments in ALT and ALL. This means that you needed to split the acquisition cost and sales proceeds for each Ardent Leisure Group Stapled Security between units in ALT and shares in ALL.
This table can be used to help you split your Ardent Leisure stapled security acquisition cost and sales proceeds between a unit in ALT and a share in ALL. This allocation between ALT and ALL has been determined by the relative net asset values of ALT and ALL as compared to the total value of Ardent Leisure Group at each reporting date.
This table provides details of the Group’s distributions under the previous stapled structure and the related tax components and DRP issue price for each distribution.