"make initial substantial holding disclosure arises where a...

"make initial substantial holding disclosure arises where a relevant interest is acquired in 5% or more "

the "or more" is the grey area.... its either 5 percent or oops we may be 8 to 10 percent before a major s/h disclosure... then there are other methods of non discloser that a buyer can take to sneak a few more % in , trusts buying for example , rio did some sneaky trading this way while accumulating another stock that i own.

if an initial t/o is rejected then i believe the rule is the company can accumulate a further 3 percent over 6 months, and in 12 months time can make another t/o offer.

i might be wrong with some of my dates/timelines though so dyor in this.