On 11 October 2010, Woolworths announced the successful completion of an off-market buy-back of its own shares. If you participated in the buy-back and you are a resident individual and you satisfy the qualified persons rule discussed in the ruling, you will have to include a dividend of $22.54 per share and an amount equal to the franking credit on the dividend component (gross up) in your income tax return. As the dividend component is fully franked, participating non-resident shareholders are not liable for Australian withholding tax.
CR 2010/62 describes the CGT consequences of participating in the Woolworths off-market share buy-back. The sale consideration per share for CGT purposes is $6.00.