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  • Appendix A – How to work out the cost base of your WAT units, WFDT units and WCL shares

    In order to work out the CGT implications of your exchange of Westfield Group stapled securities for cash and Unibail-Rodamco SE stapled securities, you need to separately work out the cost bases of your WAT units, WFDT units and WCL shares (which together make up your Westfield Group stapled securities) at the time of the CGT event on 7 June 2018.

    Most people will know how much they spent to acquire their Westfield Group stapled securities. This Appendix provides historical information for those who may need to reconstruct, or check their cost base. You can also use the Westfield Group - 2018 calculator.

    When we say 'Westfield Group stapled securities', we mean the one share and two units stapled together and acquired at or after the Westfield-Group 2004 capital-restructure, even if the identity of the relevant company and the two trusts may have changed because of previous Westfield restructures.

    In order to work out the cost base of your WAT units, WFDT units and WCL shares at 7 June 2018, you need to do the following:

    1. Work out your expenditure on acquiring the Westfield Group stapled security at the time you acquired them. For a normal purchase of securities, this will be the price paid for them. If you bought and sold parcels of securities at different times, you will have to decide which of the acquired Westfield Securities that you still had on hand at 7 June 2018. You may have to do more than one set of calculations if you had on hand Westfield securities purchased at different times.
    2. Determine the allocation of that expenditure to your WAT units, WFDT units and WCL shares by reference to the relevant Net Tangible Asset (NTA) ratio between those three entities at the time of acquiring the Westfield Securities. In this regard, you should use the NTA percentages which were last published by Westfield prior to the time of acquisition of your Westfield Group stapled security. For instance, if you acquired your Westfield Group stapled security on 15 November 2015, you would apply the NTA percentages as at 30 June 2015. This information is provided in Table 5 at the bottom of Appendix A.
    3. Reduce the cost base of your WAT units and WFDT units by relevant tax deferred distributions you received during the period you have held the Westfield Group stapled securities (that is, six monthly Westfield taxation distributions).This information is provided in Table 6 at the bottom of Appendix A. Note: WCL does not have any tax deferred distributions.
    4. Make relevant adjustments to the cost base for other relevant transactions and restructures along the way.

    There was a restructure in December 2010 and June 2014 which will affect the cost base of your stapled securities. This information is provided in Table 4 at the bottom of Appendix A.

    You can use the Westfield Group 2018 calculator to calculate your cost base information.

    Work out the cost base of each of your WAT units, WFDT units and WCL shares as at 7 June 2018 as outlined in the following.

    WAT units

    You either received your WAT units before or as a result of the Westfield 2004 capital restructure or by acquiring Westfield Group stapled securities after the Westfield 2004 capital restructure.

    If you acquired your Westfield Group stapled securities as a result of the Westfield 2004 capital restructure

    Refer to Westfield-Group 2004 capital-restructure or Class Ruling CR 2004/51 to work out the cost base of the WAT units at that time.

    Reduce the cost base of the WAT units for tax deferred distributions you received from the WAT units up until 7 June 2018.

    Example 2: Veronica acquired 10,000 WAT units on 1 May 2004 for $1.50 each. On 16 July 2004, they were consolidated into 1,500 WAT units and Veronica received a capital distribution of $1.01 for each consolidated WAT unit (see Class Ruling CR 2004/51).

    The cost base of each of the 1,500 WAT units thus became $8.99 (the consolidated cost base of $10 minus $1.01). This is reduced by the tax deferred distributions received since July 2004 ($1.6359 until the Westfield Group Restructure 2010, $0.1946 between that and the Westfield Group Restructure 2014 and $0.1207 between that and 7 June 2018). This means that the CGT cost base of Veronica’s 1,500 WAT units has been reduced to $7.04 each.

    If you acquired Westfield Group stapled securities after the 2004 capital restructure

    Work out your purchase price of acquiring the Westfield Group stapled securities.

    Find the ‘Net Tangible Assets’ percentage that matches your acquisition date of Westfield Group stapled securities. Apply the relevant percentage of your purchase price of the Westfield Group stapled security to establish the starting cost base for the WAT units.

    Reduce the cost base of the WAT units for tax deferred distributions you received from the WAT units up until 7 June 2018.

    Make relevant adjustments to the cost base for other relevant transactions and restructures along the way.

    Example 1 – Virginia)

    Virginia acquired Westfield Group stapled securities on 1 September 2015 for $10 each. On the basis of the percentage for 30 June 2015 in the NTA table, 23.40% of the acquisition price should be allocated to WAT units. Therefore, the initial cost base of each of the WAT units is $2.34. This is reduced by the 5 tax deferred distributions received by Virginia from February 2016 to February 2018 (totalling 10.9 cents).

    This means that the CGT cost base of Virginia’s WAT units on 7 June 2018 was $2.231.

    See Table 1 for calculations.

    End of example
    Acquisition date

    The acquisition date of your WAT units is the date that you acquired the Westfield Group stapled securities.

    If you acquired your Westfield Group stapled securities under the Westfield 2004 capital restructure.

    WFDT units

    You either received your WFDT units from the Westfield Group restructure on 30 June 2014 as a result of holding Westfield Trust units or from acquiring Westfield Group stapled securities after 30 June 2014.

    If you acquired your Westfield Group stapled securities before 20 December 2010

    If you received your Westfield Group stapled security under the Westfield 2004 capital restructure, refer to Westfield-Group 2004 capital-restructure or Class Ruling CR 2004/51 to work out the cost base of the WFT units you received.

    Otherwise, work out the purchase price of acquiring the Westfield Group stapled securities.

    Find the ‘Net Tangible Assets’ percentage that was last published before your acquisition date of Westfield Group stapled securities. Apply the relevant percentage of your purchase price of the Westfield Group stapled security to establish the starting cost base for the WFT units.

    Reduce the cost base of the WFT units for tax deferred distributions you received from the WFT units up until 20 December 2010.

    Recalculate the cost base of your WFT units just after 20 December 2010 as being 59% of the cost base of your WFT units immediately before 20 December 2010, as set out in the Westfield Group Restructure 2010 or Class Ruling CR 2010/77.

    Reduce the cost base of the WFT units for tax deferred distributions you received from the WFT units up until 30 June 2014.

    Calculate the cost base of the WFDT units you received under the restructure on 30 June 2014 as 53.3% of the cost base of your WFT units immediately before the WFDT units were transferred, as set out in Class Ruling CR 2014/78.

    Reduce the cost base of the WFDT units for tax deferred distributions you received from the WFDT units up until 7 June 2018.

    Example 2 – Victoria

    Victoria acquired Westfield Group stapled securities on 1 September 2005 for $6 each. On the basis of the percentage for 30 June 2005 in the NTA table, 51.95% of the acquisition price was allocated to WFT units. Therefore, the initial cost base for each of the WFT units is $3.117. This was reduced by the tax deferred distributions received by Victoria from September 2005 to December 2010 totalling $1.4016. Immediately before 20 December 2010, the CGT cost base of the WFT units was $1.7154.

    Under the Westfield Group Restructure 2010, Victoria recalculated the cost base of her WFT units just after 20 December 2010 as 59% of $1.7154, or $1.0121. This was reduced by the tax deferred distributions received by Victoria between 20 December 2010 and 30 June 2014, totalling 26.90 cents. Immediately before 30 June 2014, the CGT cost base of the WFT units was $0.7431.

    Under the Westfield Group Restructure 2014, Victoria received WFDT units on 30 June 2014. The cost base of the WFDT units was 53.3% of the cost base of Victoria’s WFT units, or $0.3961.

    The cost base of Victoria’s WFDT units was reduced by the tax deferred distributions she received between 1 July 2014 and 7 June 2018, totalling 25.74 cents.

    Immediately before 7 June 2018, the CGT cost base of Victoria’s WFDT units was $0.1387.

    See Table 2 for example calculations

    End of example

    If you acquired Westfield Group stapled securities between 20 December 2010 and 30 June 2014

    Work out the purchase price of acquiring the Westfield Group stapled securities.

    Find the ‘Net Tangible Assets’ percentage relating to your acquisition date of Westfield Group stapled securities. Based on the published information, calculate the percentage of your expenditure on acquiring the Westfield Group stapled security to allocate to WFT units.

    Reduce the cost base of the WFT units for tax deferred distributions you received from the WFT units up until 30 June 2014.

    Calculate the cost base of the WFDT units you received under the restructure on 30 June 2014 as 53.3% of the cost base of your WFT units immediately before you received the WFDT units, as set out in Class Ruling CR 2014/78.

    Reduce the cost base of the WFDT units for tax deferred distributions you received from the WFDT units up until 7 June 2018.

    Example 3 – Vivyu

    Vivyu acquired Westfield Stapled Securities on 8 April 2012 for $12 each. Based on the NTA table as at 31 December 2011, Vivyu allocates 68.50% of her the cost base towards WFT units, resulting in $8.22. Vivyu then subtracts $0.0098 to arrive at her WFT cost base of $8.2102 before the 2014 restructure.

    To obtain her cost base for her WFDT units, she multiplies her $8.2102 by 53.3% to arrive at her WFDT cost base of $4.3760 just after the 2014 restructure event. Finally, Vivyu subtracts $0.2574 for the tax deferred distributions between June 2014 and June 2018 to arrive at her cost base of $4.1186 for WFDT units just before the 7 June 2018 restructure.

    Immediately before 7 June 2018, the CGT cost base of Vivyu’s WFDT units was $4.1186.

    See Table 3 for example calculations

    End of example

    If you acquired Westfield Group stapled securities after 30 June 2014

    Work out the purchase price of acquiring the Westfield Group stapled securities.

    Find the ‘Net Tangible Assets’ percentage relating to your acquisition date of Westfield Group stapled securities. Based on the published information, calculate the percentage of your expenditure on acquiring the Westfield Group stapled security to allocate to WFDT units.

    Reduce the cost base of the WFDT units for tax deferred distributions you received from the WFDT units up until 7 June 2018.

    Acquisition date

    The acquisition date of your WFDT units will generally be the date that you acquired the Westfield Group stapled securities.

    However, if you received your WFDT units under the Westfield Group Restructure 2014, the acquisition date of the WFDT units may not be the date you acquired your Westfield Group stapled securities but 30 June 2014 if you did not chose roll-over.

    WCL shares

    You either received your WCL shares from the Westfield Group restructure on 30 June 2014 as a result of holding WHL shares or from acquiring Westfield Group stapled securities after 30 June 2014.

    If you acquired your Westfield Group stapled securities before 30 June 2014

    If you received your Westfield Group stapled securities as a result of the Westfield 2004 capital restructure, refer to Westfield-Group 2004 capital-restructure or Class Ruling CR 2004/51 to work out the cost base of the WHL shares you received.

    Otherwise, work out the cost of acquiring the Westfield Group stapled securities.

    Find the ‘Net Tangible Assets’ percentage relating to your acquisition date of Westfield Group stapled securities. Based on the published information, calculate the percentage of your expenditure on acquiring the Westfield Group stapled security to allocate to your WHL shares.

    Calculate the cost base of the WCL shares you received under the demerger on 30 June 2014 as 73.7% of the cost base of your WHL shares immediately before you received the WCL shares, as set out in Class Ruling CR 2014/78.

    Example 4 - Victoria

    Victoria acquired Westfield Group stapled securities on 1 September 2005 for $6 each. On the basis of the percentage for 30 June 2005 in the NTA table, 7.11% of the acquisition price was allocated to WHL shares. Therefore, the initial cost base for each of the WHL shares is $0.4266.

    The cost base of Victoria’s WHL shares was not affected by the Westfield Group Restructure 2010.

    Under the Westfield Group Restructure 2014, Victoria received WCL shares on 30 June 2014. The cost base of the WCL shares was 73.7% of the cost base of Victoria’s WHL shares, or $0.3144.

    Immediately before 7 June 2018, this was the CGT cost base of Victoria’s WCL shares.

    See Table 2 for example calculations

    End of example

    If you acquired your Westfield Group stapled securities after 30 June 2014

    Work out the cost of acquiring the Westfield Group stapled securities.

    Find the ‘Net Tangible Assets’ percentage relating to your acquisition date of Westfield Group stapled securities. Based on the published information, calculate the percentage of your expenditure on acquiring the Westfield Group stapled security to allocate to WCL shares.

    Acquisition date

    The acquisition date of your WCL shares will generally be the date that you acquired the Westfield Group stapled securities.

    However, if you received your WCL shares under the Westfield Group Restructure 2014, the acquisition date of the WCL shares may not be the date you acquired your Westfield Group stapled securities but 30 June 2014 if you did not chose roll-over.

    If you received your WCL shares as a result of holding WHL shares which were acquired before 16 July 2004, it may be possible that the acquisition date of your WCL shares is deemed to be before 16 July 2004.

      Last modified: 27 Aug 2018QC 56126