Ann: MoU Signed with Mali Gov & Sale of Entire Project to Ganfeng, page-744

• https://www.nortonrosefulbright.com/en/inside-africa/blog/2019/12/mali-entry-into-force-of-the-new-mining-code#
• Broader capital gains tax: the capital gains tax continues to apply to the gains generated by a direct transfer of a mining title and is further extended to an indirect transfer of such mining title, as well as to the direct and indirect transfer of shares in the capital of a titleholder. Note that capital gain tax would apply to any direct or indirect transfer of shares, irrespective of whether a change of control has occurred. Capital gains will be taxed in accordance with the provisions of the General Tax Code.