Pantoro Limited (ASX: PNR) (Pantoro, or the Company) refers to the acquisition of Tulla Resources Plc (Tulla) by means of a United Kingdom Court-sanctioned scheme of arrangement under Part 26 of the Companies Act 2006 (UK) which was implemented on 30 June 2023 (the Merger).

On 9 August 2023, the Australian Tax Office (ATO) published the attached final class ruling regarding the tax treatment of the Merger (the Ruling)

The Ruling sets out the income tax consequences for the shareholders of Tulla for the: demerger of Phoenix Industrial Minerals Pty Ltd (Phoenix) by Tulla which was implemented on 23 June 2023

The Ruling includes guidance that the cost base of Tulla shareholders' pre-Demerger Scheme holdings should be apportioned between Phoenix and Tulla based on th following percentages:Phoenix: 2.31%; Tulla: 97.69%.

The Ruling also contains guidance about the application of scrip for scrip roll-over to the Merger Scheme for Tulla shareholders.

A copy of the Ruling is attached to this announcement.

Contact:

Tel: +61 8 6263 1110

Email: admin@pantoro.com.au

This announcement was authorised for release by David Okeby, Company Secretary

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