What this ruling covers
The Australian Taxation Office has issued Class Ruling CR 2026/75. The ruling sets out the tax consequences for Australian shareholders who exchanged their shares in African Gold Ltd (ASX: A1G) for shares in Montage Gold Corp on 29 April 2026.
The exchange took place under a court-approved scheme of arrangement. Under the scheme, each African Gold share was exchanged for 0.0628 Montage Gold Corp shares.
The ruling applies from 1 July 2025 to 30 June 2026.
Scrip for scrip roll-over
Eligible shareholders who held their African Gold shares on capital account can choose a scrip for scrip roll-over. The roll-over allows any capital gain that arose from the share exchange to be deferred. The cost base of the African Gold shares carries over to the Montage Gold Corp shares received, rather than a tax liability arising at the time of the swap.
If no roll-over is chosen
If a shareholder does not choose the roll-over, any capital gain or loss from the exchange is required to be included in their tax return for the 2025-26 income year. A 50% CGT discount may apply where the African Gold shares were held for at least 12 months before 29 April 2026.
Key actions
- Shareholders who held African Gold shares (A1G) on the record date of 22 April 2026 and received Montage Gold Corp shares can review whether to choose the scrip for scrip roll-over when preparing their 2025-26 tax return.
- The roll-over is only available to shareholders who held their African Gold shares on capital account - not as trading stock or revenue assets.
- Shareholders who held their African Gold shares for at least 12 months before 29 April 2026 and do not choose the roll-over can review whether the 50% CGT discount applies to any capital gain.
- The full ruling is available at https://www.ato.gov.au/law/view/document?docid=CLR/CR202675/NAT/ATO/00001.
This is a plain-English summary for information only, not legal or compliance advice. Always check the official source or consult a qualified professional.