Depends where the tax losses ended up - with businesses transfered to MM or retained by OZL. I don't know tax law as it applies to these sorts of transactions but would not be surprised if the writedowns would stick with the businesses that generated them. Not that the ph operation or Oxiana before it would have accrued much in the way of franking credits.
On the other hand - if i am wrong and OZL has retained full tax losses of the presale entity then this could leave the new OZL with a sizable intangible asset, being the ability to defer tax until future profits exceed these losses.
An interesting topic - have there been any announcements in this area?
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