Demerger of Coles Group Limited – ATO Class Ruling

14 December 2018

Demerger of Coles Group Limited – ATO Class Ruling

The Australian Commissioner of Taxation has today issued Class Ruling CR 2018/59 (Class Ruling) covering the Australian income tax implications of the demerger of Coles Group Limited (Coles) for shareholders of Wesfarmers Limited (Wesfarmers).
The Class Ruling confirms the availability of demerger tax relief for certain Wesfarmers shareholders.

Demerger tax relief gives certain Wesfarmers shareholders the choice to defer the Australian capital gains tax (CGT) consequences that arise as a result of a Wesfarmers shareholder receiving Coles shares under the demerger. This broadly means that where a Wesfarmers shareholder chooses demerger tax relief, they will not be subject to Australian CGT until they sell their Coles or Wesfarmers shares.

The Class Ruling also confirms the dividend component of the demerger distribution of Coles shares is not subject to tax in Australia.

Wesfarmers has prepared a tax information guide to assist Australian resident shareholders of Wesfarmers in calculating the cost base allocation of their Wesfarmers and Coles shares. A copy of the tax information guide is attached to this announcement and is also made available on the Wesfarmers website.

The Class Ruling can be accessed via the Investor Centre section of Wesfarmers website at

For more information:

Cathy Bolt
Media and External Affairs Manager
+61 8 9327 4423 or +61 417 813 804

Erik du Plessis
Manager, Investor Relations
+61 8 9327 4603 or +61 439 211 630