Tulla Merger ATO Class Ruling

On 9 August 2023 the Australian Tax Office published a final class ruling regarding the tax treatment of the merger with Tulla Resources Plc (the Ruling).

The Ruling sets out the income tax consequences for the shareholders of Tulla for the:

  • demerger of Phoenix Industrial Minerals Pty Ltd (Phoenix) by Tulla which was implemented on 23 June 2023 (Demerger Scheme), and
  • scheme of arrangement between Tulla and Pantoro, which was implemented on 30 June 2023 (Merger Scheme).

A copy of the ruling can be obtained here: Class Ruling CR 2023/44