Westfield Corporation (Westfield) was created on 30 June 2014 upon the restructure of the Westfield Group (Restructure). The Restructure effectively divided the Westfield Group into two separate listed property groups , Westfield and Scentre Group and also resulted in the merger of the Westfield Retail Trust into the newly created Scentre Group. The former Westfield Group and the Restructure are described further in the History section of this website.
Westfield is a stapled group , and that means that each Westfield Security comprises three separate assets (one Westfield Corporation Limited share, one WFD Trust unit and one Westfield America Trust unit).
For Australian tax purposes the consequences of amounts paid to security holders on their Westfield Securities and the consequences of a sale of their Westfield Securities requires an analysis of what is happening in respect of each of the three stapled securities that make up the Westfield Securities.
Westfield pays distributions half yearly (see further information in the Distribution Information section of this website). The Australian tax components of the distributions received each financial year and guidance for Australian tax payers about how to record them on their tax returns are described in annual Tax Statements and Tax Guides that Westfield provides to security holders in July each year.
That information is also contained in the annual Tax Guide and Taxation Components material published on this web site.
The Tax Statements provided to security holders will describe the amount of any tax deferred distributions received.
Cost Base Issues
The Australian tax consequences of a sale or other disposal of Westfield Securities and the receipt of any tax deferred distributions will typically depend on the cost base that the security holder has in their various securities. The cost base needs to be determined in respect of each of the three different securities that make up each stapled Westfield Security and this needs to be done in respect of the various tranches of Westfield Securities the security holder has. The cost base of Westfield Securities a security holder has will be calculated in a different way depending on whether the Westfield Securities were acquired as a result of the Restructure in 2014 (described above) or were acquired after the Restructure (eg purchased on the ASX).
Security holders that acquired their Westfield Securities as a result of participating in the Restructure in 2014 will have a cost base that derives from the cost base they had in the relevant Westfield Group securities. The way to calculate that cost base is described in the two documents linked below:
Security holders that have acquired Westfield Securities since the Restructure need to set the cost base they have by allocating the cost of each Westfield Security over the separate assets that make up the stapled securities on a reasonable basis. The way this can be done, as well as the allocation of sale proceeds (to calculate any taxable gain on sale) , are described in Section 2 of the most recent Westfield Corporation Tax Guide linked below. It also describes the consequences of receiving a tax deferred distribution.
As mentioned in the Guide one reasonable way to determine cost base (and allocation of sale proceeds) is to apply a Net Tangible Asset approach in respect of the 3 stapled entities using the following information
|30 Jun 14||12.63%||75.79%||11.58%||100%|
|31 Dec 14||13.48%||66.67%||19.85%||100%|
|30 Jun 15||16.38%||60.22%||23.40%||100%|
|31 Dec 15||17.98%||50.99%||31.03%||100%|
|30 Jun 16||19.55%||49.35%||31.10%||100%|
|31 Dec 16||19.99%||45.96%||34.05%||100%|
Fund Payment Notices
Managed Investment Trusts like Westfield Corporation are required to provide some specific information about their distributions to the ASX to assist custodians to determine the amount of Australian withholding tax to deduct from on payment to investors. A record of these notices is as follows;
If I sell my Stapled Securities, how do I calculate my capital gains tax?
Westfield Corporation Stapled Security comprises three separate assets for capital gains tax purposes (one Westfield Corporation Limited share, one WFD Trust unit and one Westfield America Trust unit). For capital gains tax purposes you need to apportion the cost of each Stapled Security and the proceeds on sale of each Stapled Security over the separate assets that make up the Stapled Security. This apportionment should be done on a reasonable basis. One possible method of apportionment is on the basis of the relative Net Tangible Assets of the individual entities.
What is tax-deferred income?
WFD and Westfield America Trust pay distributions which usually contain a tax-deferred portion. We will confirm any tax deferred amounts paid to you in your annual Tax Statement.
When will I receive my annual tax statement?
These are forwarded to security holders each July. If you are searching for information about how to complete past taxt returns, please refer to the relevant Tax Guides on this website.