plainounder the true demerger rules in the tax act my...

plaino

under the true demerger rules in the tax act my understanding is that only ordinary shareholders can participate in the spin-off if it is a true spin-off. Demerger rules simply allow a CGT rollover relief for shareholders. If you want a good example to read up on I know of people who did Arafura Resources spin-off of the uranium company, and an announcement was given with step by step approach.

there are other way the company could try and spin-off without demerging.

Consolidate GAU with the new subsidiary that they have formed. transfer the asset. NO CGT considerations as CGT event eliminated at consolidation (stamp duty issues in SAF but one would think nominal). Then do a straight IPO of New Coy that anyone can participate in. However GAU would be left with a shareholding in the New Coy which SLV wouldnt want. This is what IFE did - stripped big value out of TRF in doing so.

But would think will be a clean spin-off as SLV will want nothing to do with Ni.