OreCorp Limited (ASX: ORR) (OreCorp or the Company) is pleased to advise that the Australian Taxation Office has issued Class Ruling 2022/48 (Class Ruling) in respect of the Australian income tax implications of the demerger of Solstice Minerals Limited, (Demerger) for certain shareholders of OreCorp.

The Class Ruling applies to OreCorp shareholders who received an in-specie distribution of Solstice Minerals shares, and: were registered on the OreCorp share register on 13 April 2022 (Record Date); held their OreCorp shares on capital account on the Record Date (as opposed to being held as revenue assets or as trading stock) and were residents of Australia on 22 April 2022 (Implementation Date).

The Class Ruling provides that a capital gains tax event happened upon the transfer of Solstice Minerals shares to OreCorp shareholders on the Implementation Date. The effect of the Class Ruling is that OreCorp shareholders who choose demerger tax relief: will be able to disregard any capital gain that arises from the capital reduction that occurred in connection with the Demerger and must recalculate the cost base and reduced cost base of their OreCorp shares, and calculate the cost base and reduced cost base of the corresponding Solstice Minerals shares they acquired under the Demerger.

The Commissioner accepts that a reasonable apportionment is to attribute 97.06% of the total cost base of the OreCorp shares to the OreCorp shares and 2.94% of the total cost base to the corresponding Solstice Minerals shares. The following is an illustrative example of how to calculate the cost bases for the purposes of the Class Ruling: Max held 5,000 OreCorp shares that had a total cost base of $4,000 just before the Demerger. He received 502 Solstice Minerals shares under the Demerger, being one Solstice Minerals share for every 9.9449 OreCorp shares (rounded down to the nearest share).

Contact:

Matthew Yates

Tel: +61 9381 9997

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