Ann: Presentation on Unification of BHP's DLC structure, page-6

it’s quite simple really. In layman’s terms you will simply get issued BHP ASX, and your BHP PLC shares will no longer exist. This is a benefit to you if you’re an Australian tax resident as you can utilise the franking credits. If you’re a UK tax resident it doesn’t really do anything. Their will be no withholding tax on the dividends simply because franking should cover it. However you can’t use them as a credit in the UK.

Without knowing UK tax law off the top of my head, I’d assume you’ll most likely have a CGT rollover exemption on the exchange of shares. Don’t hold me account and this isn’t advice, however tax law is normally logical on these and it’s technically a script offer with no change in beneficial ownership.

It was a stupid structure as a result of legacy operations from
the biliton merger. Good riddance! RIO should do the same thing, however I’m not holding my breathe given management and board reside in the UK and they wouldn’t want to move. Contrary to what’s technically the best idea for shareholders.