Just a thought.
Wouldn't the proposed tax mean that it is beneficial for companies like MCO to focus predominantly on exploration to build up a significant resource. Then sell the resource to overseas companies and Chinese state owned companies who can use transfer pricing to avoid the tax.
This way wouldn't shareholders get a bigger slice of the pie as well as, up until the sale, they would be generating minimum EBIT, obtain the exploration rebate and therefore avoid the tax.
Shareholders then sell their shares to the takeover company and no Super Profits Tax would be paid rather CGT tax to be paid by shareholders.
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