I agree there is some uncertainty as to how much of theses...

I agree there is some uncertainty as to how much of theses losses can offset future profits. In the 6 reporting periods since EGN has returned to profitability these tax losses have been able to be utilised so we can assume the company has met continuous ownership and same business tests to date.

I see no reason why they can't continue to meet SBT in the future as there has been no change of business in any of Engenco's subsidiaries. My understanding of this rule is that it is designed to stop practices like back-door listings to use tax losses in an entirely different business, say mining losses against telco profits.

There has been no change in ownership of Engenco (Coote) over it's subsidiaries where the losses have incurred. Its an interesting point as to the 50% change of 'ultimate owners' since the loss incurred. I am wondering how that is interpreted? Equity ownership is obviously changing on a daily basis. I am not aware of companies tracking share ownership for that purpose. In any case a large proportion of the losses have been incurred when current management and shareholders were in place dealing with the legacy issues of prior management. If all of the current carry forward losses are able to be utilised they will have a nominal benefit of approx $33M to future cash flows.