I think it will be return of capital, tax is paid in zim. There is no double treaty with Australia for tax purpose so it’s not like ato will tax psc n we have credits from zim. when the proceeds come back, it will be exempt income.
say worst case, psc has to pay tax in Australia, we can still get fully franked dividend you just have to prepaid the tax so there isn’t franking deficit.
Ann: Prospect sells interest in Arcadia for US$378M, page-167
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