Tax Information

An investment in DBI comprises an ordinary share in DBI (Share) and a loan note (Loan Note) issued by DBI and stapled together under DBI’s Constitution on a one-to-one basis (DBI Stapled Security).

Notwithstanding that the Shares and Loan Notes are stapled to one another, for Australian income tax purposes, Securityholders should be viewed as holding a Share and a Loan Note. Each Share and Loan Note should be treated each as a separate capital gains tax (CGT) asset for Australian income tax purposes.

Distributions paid in respect of DBI Stapled Securities may be paid in the form of a dividend on Shares, repayment of the principal of the Loan Notes, a return of share capital or a combination thereof.

Securityholders should refer to distribution statements provided in respect of each distribution for details of the components of distributions.

DBI’s distribution policy is to distribute between 60% and 80% of Funds From Operations (FFO), allowing for growth in the distributions in line with underlying FFO growth.

Securityholders should refer to distribution statements provided in respect of each distribution for details of the components of distributions.

DBI expects to attach franking credits to the dividend component of distributions with the maximum available franking credits permitted to under Australia’s imputation system.

The extent to which the dividend component of a distribution can be franked will depend on DBI’s franking account balance at the end of each income year.

Securityholders should refer to distribution statements provided in respect of each distribution paid for details of the components of distributions paid and franking credits attached.

The income tax implications for Securityholders associated with distributions on DBI Stapled Securities will depend on the components of the distributions and each Securityholder’s personal circumstances.

Securityholders should refer to distribution statements provided in respect of each distribution paid by DBI for details of the components of distributions paid and franking credits attached.

Further information for Australian resident Securityholders in relation to the tax treatment of distributions in the form of repayment of Loan Note principal and dividends is available below.

Loan Notes should be considered a “traditional security” for income tax purposes. Accordingly, any taxable gain or loss that may arise on repayment should be determined under section 26BB and 70B of the Income Tax Assessment Act 1936 and treated as a revenue gain or loss.

The extent to which a taxable gain or loss arises for an Australian resident Securityholder on repayment of Loan Note principal should be determined by reference to the acquisition cost allocated to the Loan Note by the Australian resident Securityholder.

Where an Australian resident Securityholder has determined that the acquisition cost of their Loan Notes is equal to the face value of the Loan Notes owed to the Australian resident Securityholder at the time of acquisition, no taxable gain or loss should arise in respect of repayments of Loan Note principal.

Where an Australian resident Securityholder determines that the acquisition cost of their Loan Notes is less than the face value of the Loan Notes owed to the Australian resident Securityholder at the time of acquisition, repayment of Loan Note principal may give rise to a taxable gain (refer to example below).

Additional information in relation to working out the acquisition cost of Loan Notes and the cost base of Shares acquired on-market and issued under the IPO is available below.

Australian resident Securityholders should include the amounts of distributions paid in the form of dividends in their taxable income in the year of receipt. Australian resident Securityholders may also be required to include any franking credits attached to dividends in their taxable income where they are entitled to a tax offset in relation the franking credits attached to the distribution.

Securityholders should obtain their own professional advice, as necessary, in connection with the completion of their tax returns and to meet their own financial situation and needs.

Securityholders should refer to distribution statements provided in respect of each distribution paid by DBI for details of the components of distributions paid and franking credits attached.

DBI Stapled Securities comprise a Share and a Loan Note issued by DBI stapled together under DBI’s Constitution on a 1 to 1 basis.

Securityholders who acquire their DBI Stapled Securities on-market are required to work out the acquisition cost of their Loan Notes and the cost base of their Shares separately for Australian income tax purposes.

Whilst it is for Securityholders to decide how to split the purchase price of their DBI Stapled Securities, Securityholders who acquired DBI Stapled Securities post IPO (i.e. on-market) may wish to allocate their purchase price as follows:

Loan Note Share
The face value of the Loan Notes owed to the holder at the time of acquisition
Remainder of the purchase price after allocation of the Loan Note

Information about the face value of the Loan Notes is available below.

The Face Value of a Loan Note is the amount DBI must repay to a Securityholder in respect of each of their DBI Stapled Securities on the Loan Note maturity date of 30 September 2030.

A summary of the face value of the Loan Notes since IPO is available on our Distributions page here.

Securityholders who were issued Loan Notes as part of the Initial Public Offering of DBI Stapled Securities acquired their Loan Notes for their initial face value, being $0.80 per Loan Note. The remaining balance of the issue price of $2.57 (i.e., $1.77) should be allocated to the Shares.

This example sets out the potential income tax implications associated with an Australian Securityholders allocating an acquisition cost to their Loans Notes which is less than the face value of their Loans Notes.

Securityholders should obtain their own professional advice, as necessary, in connection with the completion of their tax returns and to meet their own financial situation and needs.

An Australian resident Securityholder acquired DBI Stapled Securities on-market for $2.40 per Stapled Security. At the time of acquisition, the amount payable to the Securityholder on maturity date (i.e. face value) of the Loan Notes comprising part of each Stapled Security was $0.80. The Securityholder determined that the acquisition cost for their Loan Notes and Shares comprising their DBI Stapled Security was as follows:

DBI subsequently paid a distribution of 4.5 cents per Stapled Security as a partial repayment of principal on the Loan Notes comprising part of the Stapled Securities. The partial repayment of principal of the Loan Notes reflected 5.62% of the outstanding principal on the Loan Note at the Record Date of the distribution ($0.045 / $0.80 = 5.63%).

The Securityholder determines that partial repayment of Loan Notes are redemptions of traditional securities on the basis that the repayment discharges DBI’s liability to pay an amount of the Loan Note face value equal to the repayment.

The Securityholder calculates their taxable gain on receipt of the distribution by working out the proportionate cost of each of their Loan Notes attributable to the principal repaid on each Loan Note and subtracts this from the distribution received per Loan Note.

The Securityholder works out the cost of the part of the Loan Note being repaid as a proportion of the cost they to allocated to their Loan Note, which is equal to the proportion of the face value of the Loan Note being repaid (i.e. 5.63%). 

The Securityholder calculates the proportion of the face value of the Loan Note being repaid as the amount of principal of the Loan Note being repaid divided by the face value of the Loan Note at the record date of the distribution ($0.045 / $0.80 = 5.63%). The Securityholder’s cost of the part of the Loan Note which is repaid is therefore $0.028 (calculated as $0.50 * 5.63%).

The Australian resident Securityholder includes the gain of $0.017 per Stapled Security in their tax return as taxable income for the income year in which they received the distribution.