Ann: MIN: Atlas Iron Ltd - Redstone Offer, page-122

It's the company that pays tax not the shareholders. Yes we get no tax credits on dividend as the company pays no tax on first 500mill of profit. If AGO is held by Twiggy and Gina and Us then there is no loss of tax credits just benefits the company. Everyone benefits from AGO not paying tax for first few years. We wont worry about not getting a dividend if the first 500 mill of profits is invested on making the company stronger and therefore a far higher shareprice.
Transferring AGO into part of another company then yes potentially the tax benefit would be lost especially if not owned outright.