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The demutualisation of the life offices (AMP, National Mutual and Colonial Mutual) has significantly boosted market capitalisation and increased the number of shareholders over the past twenty years. The big advantage for members has been the exchange of an interest that could not be traded, for shares that are listed on the Australian Securities Exchange.
However, when they come to sell those shares, as a general rule, shareholders are subject to Capital Gains Tax. Even though nothing was paid for the shares, they have a value for CGT purposes, which is reflected as “Acquisition Cost per share” in the table below. That acquisition cost may be only a part of the cost base which can be deducted from the capital proceeds to arrive at the capital gain. The cost base may also include costs associated with the sale of the shares such as fees paid to a broker.
Changes for private health insurers
Effective 1 July 2007, changes were made to the law relating to the capital gains tax (CGT) treatment of policy holders of health insurers who receive cash or shares when their health insurer demutualises. Under the new law, policy holders disregard any capital gains and losses that arise when a private health insurer demutualises.
The changes apply for example to the demutualisation of NIB, MBF and AHM, see table below.
Changes for friendly societies
Capital gains and capital losses arising to members and insured entities when their friendly society demutualises to a for‑profit entity will be disregarded except when the member or insured entity receives an amount of money under the demutualisation.
Below is a small selection of demutualisations of the past twenty eight years. For the full table please click on the link below.
DEMUTUALISATIONS 1985-2023 (to 31/12/2023) Last updated: 05 January 2024 |
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Company
|
Acquisition Cost per share | Acquisition Date |
Notes (see below)
|
AMP Ltd |
$10.43
|
20 November 1997
|
1
|
Australian Co-operative Foods Limited |
Cash only |
26 November 2008 |
13 |
Australian Health Management Group (AHM) |
Cash only |
14 January 2009 |
11 |
Australian Stock Exchange Ltd |
N/A
|
October 1998
|
2
|
AXA (formerly National Mutual Life) |
$1.14
|
8 August 1995
|