On 22 July 2020, the Australian Taxation Office (ATO) issued Taxation Determination TD 2020/6 (TD 2020/6) which outlines the ATO’s views regarding the application of certain aspects of the demerger relief provisions in Division 125 of the Income Tax Assessment Act 1997 (Cth). TD 2020/6 applies both retrospectively and prospectively and, as a consequence, there is now some uncertainty as to whether demerger relief applied to certain restructures of the ASC Group undertaken by its Shareholder. ASC is currently assessing whether TD 2020/6 could have any impact in this regard.