RE: Solgold Finance AG2 Oct 2021 14:07
Hi Zoros. Honestly I don't know exactly what it means. However I thought it was worth discussing this (and it didn't seem to have been mentioned since the structure was laid out in the annual report) for a few reasons.
- it seems to be tax efficient. UK has no tax treaty with Ecuador, so Solg Plc as a UK entity would I assume be liable for full Ecuadorian WHT on any capital gains, divs, interest etc that it receives from its Ecuadorian subsidiaries. Switzerland however does have a tax treaty with Ecuador, which should limit the withholding tax payable on any funds sent from Ecuador back up to the Swiss AG.
- NM had said in the past that selling Alpala would not be tax efficient. So could this new structure suggest that they are making it more tax efficient if they do need to sell off any of their interests in Ecuador?
- one of the directors of the AG board, is a guy who works for their specialist adviser Bluequest, which was appointed to advise them on concentrate marketing and related topics. I just thought this was interesting, they really are making sure they are fully set up to become a producer and are lining up the necessary expertise to market what they produce.
- I assume this entity and the adviser's expertise is being put in place with a view to financing Alpala.
- some people think that Solgs aim is to negotiate or encourage a takeover. And that they are going through the motions of becoming a producer in anticipation of being taken over. I don't think this is the case. I think Solg Is actually set on becoming a producer. But if they get taken over by a major in the meantime, well that's fine so long as the price is high enough.