At the annual meeting of APA in October 2004, securityholders approved changes to the Australian Pipeline Trust (APT) constitution to enable APA to staple securities of another entity to APT units.
Historically APT was a taxpaying public trading trust, with securityholders generally receiving after-tax distributions of income together with periodic returns of capital.
In December 2006, APT Investment Trust (APTIT) was stapled to APT to act as a pass-through trust for tax purposes. A pass-through trust is not required to pay tax on its income and as a result distributions are made pre-tax. Distributions in excess of taxable income resulting from tax timing differences can also be passed through to securityholders as tax deferred income. APTIT is therefore generally able to make higher cash distributions out of the income it receives and also return capital on which tax is deferred until units are sold.
APA believes that the stapled structure allows maximum distribution flexibility to securityholders allowing them to obtain higher cash distributions than would otherwise be the case.