Massively high tax %

Can anyone explain why Praemium's tax rate is so high?

When I try to understand their 1H results, I figure ...

- their group tax rate of >70% of earnings is of course largely driven by losses offshore offsetting Australian profits (but not offseting Australian tax liabilities)
- they report a first half loss in Europe and Asia (so shouldn't be any tax there).
- they report 1H Australian earnings of $4.964M, so even if I assume there are no R&D offsets tax, you'd expect tax to be <$1.49M (being 30% of $4.964, but I'd assume they should only be paying 27.5% given the size of their business)

Yet, they report 1H tax liabilities of $1.976M, $500K more than I'd expect.

Also, they report a whooping ~$47M in accumulated tax losses. These must be in OS jurisdictions or poorly structured within the business as they're paying tax in Australia.

With such high (assumed) OS tax losses, I really can't understand why they are transferring fees from UK business (that's making a loss) to an Australian parent (that's making a profit and so paying tax on these fees). Surely they could come up with a better commercial relationship that helps both the subsidy and the parent with fees paid once the subsidy starts making a profit? I presume after paying tax the Australian business is then transferring cash back into the UK subsidy to finance its losses?

I put in a couple of calls last week to their CFO - but the promise to return my calls hasn't happened.

Any clues/knowledge from others would be appreciated!