Ann: Sale of Solaroz Lithium Project for A$97 Million, page-282

they would have structured it as a takeover with a spinoff if they wanted to distribute the cash. ie SOL takeover of Perpetual and demerge Perpetual Asset Management at the same time (takeover of LEL and demeger Axon in this case). SRK has made gains on its previous sales of LEL at 80c but it hasn't had to pay tax on any of it due to its accumulated losses. but having Solaroz sold at the asset level means some sort of tax would be paid in Argentina before distributing to shareholders.