Perpetual (ASX:PPT) was notified by the Australian Taxation Office (ATO) that the entire cash proceeds from the proposed sale of its wealth management and corporate trust businesses will be taxed to shareholders, according to a Tuesday filing with the Australian bourse.

In May, the company entered a scheme implementation deed with an affiliate of investment firm Kohlberg Kravis Roberts to acquire its Wealth Management and Corporate Trust businesses via a scheme of arrangement for AU$2.18 billion.

The ATO said that section 45B of the Income Tax Assessment Act will apply to the scheme where the entire cash proceeds from the sale would be deemed as an assessable unfranked dividend for shareholders and would subject them to tax at the applicable rates.

The office has also declined to rule out the application of Part IVA, which could lead to an additional corporate tax liability of AU$488 million for the company, excluding penalties and interest, the filing said.

The investment fund now estimates taxes and duties from the scheme to range between AU$493 million to AU$529 million, compared with its previous assessment of AU$106 million to AU$227 million.

The estimated cash proceeds to shareholders from the deal would also reduce to AU$5.74 to AU$6.42 per share, from the company's previously expected range of AU$8.38 to AU$9.82, the filing added.

Perpetual and KKR are continuing discussions to assess the potential impact of these tax issues on the transaction.

In the same filing, the company reported a 3% increase in assets under management to AU$22.3 billion in the first quarter of fiscal 2025 for its asset management division.

The company also reported a 1% increase in corporate trust funds under administration to AU$1.2 trillion and a 3% increase in its wealth management funds under advice to AU$20.4 billion.

Perpetual's shares fell past 7% in recent Tuesday trade.

Price (AUD): $20.32, Change: $-1.59, Percent Change: -7.26%