Section 295 (3A)(vi) of the Corporations Act 2001 defines tax residency as having the meaning in the Income Tax Assessment Act 1997. The determination of tax residency involves judgement as there are different interpretations that could be adopted, and which could give rise to a different conclusion on residency. In determining tax residency, the consolidated entity has applied for following interpretations: – Australian tax residency T he consolidated entity has applied current legislation and judicial precedent, including having regard to the Tax Commissioner’s public guidance in Tax Ruling TR 2018/5 – Foreign tax residency W here necessary, the consolidated entity has used independent tax advisors in foreign jurisdictions to assist its determination of tax residency to ensure applicable foreign tax legislation has been complied with (see section 295(3A)(vii) of the Corporations Act 2001). St George Mining provides the tax residency of its subsidiaries below: Name of Entity Type of Entity Trustee, partner or participation in JV % of share capital Country of incorporation Australia resident of foreign resident Foreign jurisdiction(s) of foreign residents Desert Fox Resources Pty Ltd Body corporate Not Applicable 100% Australia Australian Not Applicable Blue Thunder Resources Pty Ltd Body corporate Not Applicable 100% Australia Australian Not Applicable Destiny Lithium Pty Ltd Body corporate Not Applicable 100% Australia Australian Not Applicable Niobium Dragon Pty Ltd Body corporate Not Applicable 100% Australia Australian Not Applicable Lithium Star Pty Ltd Body corporate Not Applicable 90% Australia Australian Not Applicable Lithium Blue Pty Ltd Body corporate Not Applicable 100% Australia Australian Not Applicable Consolidated Entity Disclosure Statement 50 St George Mining Limited Annual Report 2024
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