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Ruling confirms capital return treatment – no dividend or assessable income – for shareholders who held FireFly shares on capital account
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PERTH, Australia, June 03, 2026 (GLOBE NEWSWIRE) — FireFly Metals Ltd (ASX: FFM, TSX: FFM) (FireFly or the Company) is pleased to announce that the Australian Taxation Office (ATO) has published Class Ruling CR 2026/30 (ATO Class Ruling) confirming the Australian income tax treatment of the reduction of FireFly’s share capital effected by way of the in-specie distribution of shares in Bellavista Resources Ltd (ASX:BVR) (Bellavista) to eligible FireFly shareholders (In-specie Distribution).
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The In-specie Distribution completed on 11 May 2026 (Payment Date) and involved the transfer to eligible FireFly shareholders of 60 million1 ordinary shares in Bellavista that were received by FireFly on 29 April 2026 at completion of the transaction announced on 2 February 2026 for the sale to Bellavista of the Pickle Crow and Sioux Lookout Projects in Ontario.
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The ATO Class Ruling applies to certain classes of FireFly shareholders, including those who, on the record date of 4 May 2026 (Record Date), held their FireFly shares on capital account and were not ‘temporary residents’ of Australia on the Payment Date (Class Ruling Shareholders). Shareholders should review the ATO Class Ruling and seek independent advice where appropriate to confirm whether they are included as a Class Ruling Shareholder.
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The ATO Class Ruling confirms the information in section 4.13 of the Explanatory Memorandum in the Notice of General Meeting announced by the Company on 23 March 2026 (Explanatory Memorandum), regarding the likely Australian income tax implications of the In-specie Distribution.
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In particular, the ATO Class Ruling confirms that the In-specie Distribution constituted a return of FireFly’s share capital of 4.5 cents per FireFly share (Capital Return). The Capital Return is not a dividend,2 and no part of the Capital Return is included in the assessable income of a Class Ruling Shareholder under subsection 44(1) of the Income Tax Assessment Act 1936 (Cth) (Act). The ATO has also confirmed that the anti-avoidance provisions in sections 45, 45A and 45B of the Act will not be applied to treat any part of the Capital Return as an unfranked dividend.
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The table below summarises the key Australian income tax outcomes for Class Ruling Shareholders confirmed by the ATO Class Ruling.
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| Capital Return | The Capital Return of 4.5 cents per FireFly share is not a dividend and is not included in a Class Ruling Shareholder’s assessable income. The cost base of each FireFly share held on the Payment Date is reduced (but not below nil) by the amount of the Capital Return. If the Capital Return for a FireFly share exceeds its cost base, the excess is a capital gain for the year ended 30 June 2026. The capital gain may be eligible for the CGT discount where the FireFly share was held for at least 12 months. No capital loss can arise on the Capital Return. Class Ruling Shareholders who held FireFly shares on the Record Date but had disposed of them prior to the Payment Date will instead make a capital gain to the extent the Capital Return exceeds the cost base of their right to receive it. |
| Cost base of Bellavista shares | The cost base of each Bellavista share received under the In-specie Distribution is 58 cents, being the market value of a Bellavista share on the Payment Date. |
| Acquisition date of Bellavista shares | For CGT purposes, Bellavista shares received under the In-specie Distribution are taken to have been acquired on the Payment Date (11 May 2026). |
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