BHP transfer of Oil & Gas Div. to Woodside. A taxable transaction?????

I'm having trouble getting my head around this transaction.
I believe that BHP Oil and Gas is nearly equal in capitalization to Woodside.
The number of Woodside shares on issue is going to double. Those shares a going to BHP shareholders.
Paid as an Inspecie dividend. That is TAXABLE?????

It seems to me that I owned a piece of BHP Oil and Gas.
BHP gave that piece to Woodside in exchange for shares.
So why weren't those shares given to BHP shareholders free of tax.
Just like S32 shares were given.

Can somebody please explain to this dope how it all works?

I have a sizeable parcel of BHP shares (more than most). Im an ex BHP shareplan person.
Shares are all held outside of Super etc.
None of my so called clever mates can explain to me. Lol

One thing keeps coming into my mind - Rollover relief!.
Is the lack of Rollover Relief the reason transaction is taxed?
$10 Billion worth of Franking Credits might be the reason transaction was brought forward to this financial year?
ALP would love to get their hands on our Franking Credits!

Im looking forward to a simple explanation Re the transaction.

Article in SMH - "Merger deal may come with nasty tax surprise"
Many BHP shareholders could be in for a shock at tax time. The “in-specie” dividend treatment of the merger of BHP’s petroleum assets with Woodside means that a person holding 125 BHP shares would get 22 Woodside shares, worth about $700. This would have a $300 imputation credit, bringing up the gross dividend to $1000. For a person earning more than $180,000, this means that an additional $170 tax needs to be paid. On the upside, a person earning less than $45,000 would receive a refund of imputation credits. BHP is not saying much about this when many of its employees have shares through various employee share schemes, and would be significantly impacted by it. Surely, the earlier they know about it the better they can be prepared to find the additional tax. A BHP spokesperson points out there are two key points to make relating to the merger. The first is that everything BHP does is for shareholders, and the rationale for the deal is based on what is best for investors and for the company over the long term.

There NOT KIDDING!!!!!! Re the Tax.