Retail Entitlement Offer Booklet and Covering Letter - AJ Lucas

120602_Funnelweb_Retail Entitlement Offer v1.doc
3. Australian taxation considerations
Set out below is a general summary of the Australian income tax, goods and services tax (GST) and stamp duty
implications associated with the subscription of New Shares and the subscription of Additional New Shares for
certain Eligible Retail Shareholders (for the purposes of this Section 3, collectively the Transactions).
The tax implications associated with the Transactions will vary depending on your particular circumstances. Neither
AJL nor any of its officers or employees, nor its taxation or other advisers, accepts any liability or responsibility in
respect of any statement concerning taxation consequences, or in respect of the taxation consequences.
The comments in this section deal only with the Australian taxation implications associated with the Transactions if
you:
are a resident for Australian income tax purposes; and
hold your Shares on capital account.
The comments do not apply to you if you:
are not a resident for Australian income tax purposes; or
hold your Shares as revenue assets or trading stock (which will generally be the case if you are a bank, insurance
company or carry on a business of share trading); or
acquired the Shares in respect of which the Retail Entitlements are issued under any employee share scheme or
where the New Shares (and any Additional New Shares) are acquired pursuant to any employee share scheme.
This taxation summary is necessarily general in nature and is based on the Australian tax legislation and
administrative practice in force as at the date of this Retail Offer Booklet. It does not take into account any financial
objectives, tax positions, or investment needs of Eligible Retail Shareholders. As the taxation implications
associated with the Transactions will vary depending upon your particular circumstances, you should seek and rely
upon your own professional tax advice before concluding on the particular taxation treatment that will apply to you.
3.1 Issue of Retail Entitlements
The issue of the Retail Entitlements should not, of itself, result in any amount being included in your assessable
income.
3.2 Exercise of Retail Entitlements and applying for Additional New Shares
If you take up (ie exercise) all or part of your Retail Entitlement, you will acquire New Shares. You will also acquire
Additional New Shares if your application for Additional New Shares in accepted. The cost base (and reduced cost
base) for capital gains tax (CGT) purposes of each New Share and Additional New Share will be equal to the Offer
Price for those New Shares and Additional New Shares (respectively) plus certain non-deductible incidental costs
you incur in acquiring them.
No income tax or capital gains tax liability will arise for you on the exercise of your Retail Entitlement.
3.3 Dividends on New Shares and Additional New Shares
Any future dividends or other distributions made in respect of New Shares and Additional New Shares will be
subject to the same income taxation treatment as dividends or other distributions made on existing Shares held in the
same circumstances.
NOT FOR DISTRIBUTION OR RELEASE IN THE UNITED STATES
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