Agreed. LLL is selling 40% shares of MLBV, which is incorporated...

Agreed. LLL is selling 40% shares of MLBV, which is incorporated in the Netherlands. The Malian company LMSA, which holding Goulamina permit, remains unchanged in terms of share structure.

From the following link, it seems the CGT is tax exempted in Dutch. Just think why the JV holding company was incorporated in Dutch rather than any other countries 2 years ago? I do not think it is randomly chosen. It must have tax benefits.

Source:
https://taxsummaries.pwc.com/netherlands/corporate/income-determination

Capital gains

Capital gains are taxed as ordinary income. However, capital gains realised on disposal of shares qualifying for the participation exemption are tax exempt (see Dividend income below).

The gain on disposal of depreciable assets may be carried over to a special tax deferral reinvestment reserve but must then be deducted from the acquisition cost of the later acquired assets. Except in special circumstances, the reserve cannot be maintained for more than three consecutive years. If the reserve has not been fully applied after three years, the remainder will be added to the taxable profit.

Capital losses are deductible unless attributable to the disposal of a shareholding qualifying for the participation exemption.

Dividend income

Subject to meeting the conditions for the participation exemption, a Dutch company or branch of a foreign company is fully exempt from Dutch tax on all benefits connected with a qualifying shareholding, including cash dividends, dividends in kind, bonus shares, hidden profit distributions, capital gains, and currency exchange results. As of 1 January 2022, there are rules to prevent mismatches that may occur from applying the arm’s-length principle in international groups.

Participation exemption

The participation exemption will apply to a shareholding in a Dutch company if the holding is at least 5% of the investee’s capital, provided the conditions are met.

As a general rule, the participation exemption is applicable as long as the participation is not held as a portfolio investment. The intention of the parent company, which can be based on the particular facts and circumstances, is decisive. Regardless of the company’s intention, the participation exemption is also applicable if the sufficient tax test (i.e. the income is subject to a real profit tax of at least 10%) or the asset test (i.e. the subsidiary's assets do not usually consist of more than 50% of portfolio investments) is met.