The background to this corporate action is as follows:
BHP had a dual-listed corporate structure that consists of two companies (BHP Group PLC in the UK and BHP Group Limited in Australia), with separate legal structures and share registers. The intention is to transition to one company (BHP Group Limited in Australia) with one legal structure and share register (see
Figure 1).
Figure 1: The impact of the proposed corporate action on BHP Group
Source: BHP Billiton
What are the tax implications for BHP shareholders on the JSE?
This unification will be deemed a capital gains tax event.
What are the listing implications for BHP shareholders on the JSE?
BHP will maintain its secondary listing on the Johannesburg Stock Exchange (“JSE”). Shareholders will have their shares exchanged on a 1:1 basis for BHP Group Limited shares.
When will unification happen?
See the pertinent dates in
Figure 2 below.
Figure 2: BHP Group unification - relevant dates
| Date |
Event |
| 20 January 2022 |
Shareholder votes |
| 28 January 2022 |
PLC shares will stop trading |
| 31 January 2022 |
New BHP shares start trading in the UK and SA (unification complete) |
Source: BHP Group
IF YOU ARE A PROVISIONAL TAXPAYER, IT IS IMPORTANT TO INCLUDE THIS CAPITAL GAIN IN YOUR second PROVISIONAL TAX RETURN.
If you have any queries, please contact your
local Moore office.