Sounds good in theory but ...I asked ChatGPT (not the best...

Sounds good in theory but ...

I asked ChatGPT (not the best source but the easiest way to get info):

Q: are there restrictions by FIRB about foreign nationals owning shares in Australian companies
A: FIRB has different thresholds for foreign investment depending on the type of company and the nature of the investment. For example, if a foreign investor wants to acquire a substantial stake in a company (typically 20% or more), this might trigger a review if the company is considered a sensitive or strategic asset.
(there are other points - but this was the most relevant)

Q: what are the current thresholds for lithium mining companies
A:

General Thresholds:

• For Private Companies: Foreign investment in a private Australian company involved in lithium mining typically requires FIRB approval if the investor's stake will be 10% or more.
• For Public Companies: Foreign investment in a publicly listed company that holds mining interests generally requires FIRB approval if the investment is 20% or more.

Sensitive Sectors:

• Lithium mining is considered a strategic sector due to the increasing importance of lithium in battery technology and renewable energy. Therefore, even if the investment is below the standard thresholds, it may still attract scrutiny, especially if the investor is from a country with which Australia has particular economic or security concerns.

Specific to Mining:

• The Australian government is particularly vigilant about foreign investments in mining and resources sectors due to their strategic importance. As such, the FIRB might apply additional scrutiny or lower thresholds depending on the nature and scale of the investment.

Q: can multiple foreign investors acquire 19% each of an Australian public lithium mining company
A:

FIRB Approval:

• Each individual foreign investor holding 19% would generally not trigger FIRB approval on their own, as the threshold for requiring FIRB approval is typically 20% or more of the shares in a public company.
• However, if these investors are acting in concert or there is a coordinated approach that results in a combined holding exceeding 20%, FIRB approval might be required.

Acting in Concert:

• If the investors are seen as working together or if there is evidence of a coordinated effort to control or influence the company, the total combined holding could be scrutinized. FIRB might review the investment if it is determined that the investors are effectively operating as a group.

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There is more, but overall it does not seem to be difficult to circumvent the FIRB.