i would await a CR (Class Ruling) from the ATO. I haven't looked yet, but that is the usual situation. I would assume that the ROL shares would be deemed an unfranked dividend. It's a different situation to a divestment of assets - this is a distribution of investments held.
Anyway, awaiting the ATO's decision would be a wise move.
Cheers,
Split
tax treatment, page-4
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