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Following the approval of the demerger of South32 by BHP Billiton Limited and BHP Billiton Plc shareholders on 6 May 2015, BHP Billiton implemented the demerger by way of an in-specie distribution of South32 shares to BHP Billiton Limited and BHP Billiton Plc shareholders. The South32 shares have since begun trading independently from BHP Billiton shares.

Section 8 of the Shareholder Circular contains disclosure of the general tax consequences of the demerger for certain shareholders and ADS holders of BHP Billiton Limited that are tax resident in Australia, New Zealand, the UK or the US, and of BHP Billiton Plc that are tax resident in the UK, the US or South Africa. Additional guidance as to the market value of the South32 shares for tax reporting purposes is made available to certain shareholders and ADS holders resident in the jurisdictions listed below.

This guidance assumes that the reader has read Section 8 of the Shareholder Circular (PDF 5.63 MB). It does not constitute tax advice and must not be relied upon as such.

All shareholders and ADS holders of BHP Billiton, including those resident in other jurisdictions not mentioned below, should review Section 8 of the Shareholder Circular and consult with their own independent taxation advisers to confirm the specific taxation implications of participating in the demerger that apply to them, in light of their particular circumstances.

Residence of shareholder

Link to further taxation information

Australia

Additional taxation guidance including the ATO Class Ruling CR 2015/40 (PDF 331 kb) for Australian resident shareholders of BHP Billiton Limited is available here (PDF 89 kb).

New Zealand

Additional taxation guidance in respect of market value for New Zealand resident shareholders of BHP Billiton Limited is available here (PDF 19 kb).

United Kingdom

Additional taxation guidance in respect of market value for UK resident shareholders of BHP Billiton Plc is available here (PDF 19 kb).

United States

Additional taxation guidance in respect of market value for US resident shareholders and ADS holders of BHP Billiton Plc and BHP Billiton Limited is available here (PDF 14 kb).

South Africa

Additional taxation guidance in respect of market value for South African resident shareholders of BHP Billiton Plc is available here (PDF 21 kb).

Canada

Additional taxation guidance in respect of market value for Canadian resident shareholders of BHP Billiton Limited is available here (PDF 75 kb).


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