Ann: Target's Statement and Independent Expert's Report, page-55

Stefans said: "To utilize the accumulatrd tax losses AGO, or the acquirer or AGO, must continue the current business and produce profit."

DYOR:
That is correct.
Atlas is in the iron ore and diversified minerals business (Fe, Li. Mn).
HPPL/FMG/BHP/RIO are also in iron ore business.
BHP/RIO are also in the diversified minerals business.

Surely the smart and high paid lawyers that work for HPPL/FMG/BHP/RIO can work it out.