Troy made a lot of losses by devalueing mining assets. For tax credits only real losses, mostly operating losses, have to be counted. It is ca. A$100m and at 30% tax rate it is worth A$30m. Half of it seems to be in Guyana though.
Also the royalty in Guyana, a hefty 8%, can be deducted from taxes by special agreement. I don't know if Troy had to tax earnings in Australia and how it would be handled under a double taxation agreement.
I think the Troy entities with existing agreements are way better than anything a newcomer could come up with today.
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