ATO Class Ruling for FireFly’s in-specie distribution of Bellavista shares
ASX: FFM | TSX: FFM
Company Announcement
3 June 2026
FireFly Metals Ltd
+61 8 9220 9030
www.fireflymetals.com.au
ACN: 110 336 733
Principal & Registered Office:
Level 2/8 Richardson Street West Perth WA 6005
ATO Class Ruling for FireFly’s in-specie
distribution of Bellavista shares
Ruling confirms capital return treatment – no dividend or assessable income – for
shareholders who held FireFly shares on capital account
FireFly Metals Ltd (ASX: FFM, TSX: FFM) (FireFly or the Company) is pleased to announce that the
Australian Taxation Office ( ATO) has published Class Ruling CR 2026/ 30 (ATO Class Ruling )
confirming the Australian income tax treatment of the reduction of FireFly’s share capital eff ected
by way of the in-specie distribution of shares in Bellavista Resources Ltd (ASX:BVR) ( Bellavista) to
eligible FireFly shareholders (In-specie Distribution).
The In-specie Distribution completed on 11 May 2026 ( Payment Date) and involved the transfer to
eligible FireFly shareholders of 60 million1 ordinary shares in Bellavista that were received by FireFly
on 29 April 2026 at completion of the transaction announced on 2 February 2026 for the sale to
Bellavista of the Pickle Crow and Sioux Lookout Projects in Ontario.
The ATO Class Ruling applies to certain classes of FireFly shareholders, including those who, on the
record date of 4 May 2026 (Record Date), held their FireFly shares on capital account and were not
‘temporary residents’ of Australia on the Payment Date (Class Ruling Shareholders). Shareholders
should review the ATO Class Ruling and seek independent advice where appropriate to confirm
whether they are included as a Class Ruling Shareholder.
The ATO Class Ruling confirms the information in section 4.13 of the Explanatory Memorandum in
the Notice of General Meeting announced by the Company on 23 March 2026 (Explanatory
Memorandum), regarding the likely Australian income tax implications of the In -specie
Distribution.
In particular, the ATO Class Ruling confirms that the In-specie Distribution constituted a return of
FireFly's share capital of 4.5 cents per FireFly share ( Capital Return). The Capital Return is not a
dividend,2 and no part of the Capital Return is included in the assessable income of a Class Ruling
Shareholder under subsection 44(1) of the Income Tax Assessment Act 1936 (Cth) (Act). The ATO
has also confirmed that the anti -avoidance provisions in sections 45, 45A and 45B of the Act will
not be applied to treat any part of the Capital Return as an unfranked dividend.
1 Minus 2,883 Rounding Shares as set out in the Explanatory Memorandum.
2 As ‘dividend’ is defined in subsection 6(1) of the Income Tax Assessment Act 1936 (Cth).
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The table below summarises the key Australian income tax outcomes for Class Ruling Shareholders
confirmed by the ATO Class Ruling.
Capital Return The Capital Return of 4.5 cents per FireFly share is not a dividend and is not
included in a Class Ruling Shareholder's assessable income.
The cost base of each FireFly share held on the Payment Date is reduced (but not
below nil) by the amount of the Capital Return. If the Capital Return for a FireFly
share exceeds its cost base, the excess is a capital gain for the year ended 30
June 2026. The capital gain may be eligible for the CGT discount where the
FireFly share was held for at least 12 months. No capital loss can arise on the
Capital Return.
Class Ruling Shareholders who held FireFly shares on the Record Date but had
disposed of them prior to the Payment Date will instead make a capital gain to
the extent the Capital Return exceeds the cost base of their right to receive it.
Cost base of
Bellavista shares
The cost base of each Bellavista share received under the In-specie Distribution
is 58 cents, being the market value of a Bellavista share on the Payment Date.
Acquisition date of
Bellavista shares
For CGT purposes, Bellavista shares received under the In-specie Distribution are
taken to have been acquired on the Payment Date (11 May 2026).
Foreign-resident Class Ruling Shareholders can generally disregard any capital gain made on the
Capital Return, unless their FireFly shares (or their right to receive the Capital Return) are taxable
Australian property.
Class Ruling Shareholders should refer to the full text of t he ATO Class Ruling, which can be
accessed from the ATO website at the following link: www.ato.gov.au/law.
The information in this announcement is a summary in nature. Tax consequences of the In-specie
Distribution may vary depending upon the individual circumstances of FireFly shareholders. The
Company recommends that FireFly shareholders obtain independent tax advice specific to their
circumstances regarding the tax consequences of the In-specie Distribution.
Distribution of Bellavista Shares and Cash Proceeds
On 11 May 2026, e ligible FireFly shareholders 3 were transferred 1 Bellavista share for approximately
every 12.8 FireFly shares held on the Record Date, subject to rounding adjustments . Holding
statements for such Bellavista shares were despatched on 11 May 2026.
Following the sale of the relevant Bellavista shares, ineligible FireFly shareholders received cash
proceeds, less costs and expenses in connection with the sale , of $0.546975 for each Bellavista
share they would have been entitled to be distributed had they been eligible FireFly shareholders .
Payment to ineligible FireFly shareholders was despatched on 27 May 2026.
3 Eligible FireFly shareholders are those who had a registered address on the Record Date in one of the eligible jurisdictions
set out in section 2.4 of the Explanatory Memorandum and who were entitled to receive a distribution of Bellavista shares
which constituted a marketable parcel (being a parcel of Bellavista shares with a market value of at least A$500) as of the
Record Date.
ASX: FFM | TSX: FFM
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This announcement has been authorised by the FireFly Board of Directors.
Contact information:
Steve Parsons
Managing Director
FireFly Metals Ltd
+61 8 9220 9030
Jessie Liu-Ernsting
Chief Development Officer
FireFly Metals Ltd
+1 709 800 1929
Media
Paul Armstrong
Read Corporate
+61 8 9388 1474
ABOUT FIREFLY METALS LTD
FireFly Metals Ltd (ASX, TSX: FFM) is an emerging copper-gold company focused on advancing the
high-grade Green Bay Copper -Gold Project in Newfoundland, Canada. The Green Bay Copper -
Gold Project currently hosts a Mineral Resource prepared and disclosed in accordance with the
2012 Edition of the Australasian Code for Reporting of Exploration Results, Mineral Resources and
Ore Reserves ( JORC Code 2012 ) and Canadian National Instrument 43 -101 - Standards of
Disclosure for Mineral Projects (NI 43-101) of 50.4Mt of Measured and Indicated Mineral Resources
at 2.0% for 1,016Kt copper equivalent (CuEq) and 29.3Mt of Inferred Mineral Resources at 2.5% for
722Kt CuEq. The Company has a clear strategy to rap idly grow the copper-gold Mineral Resource
to demonstrate a globally significant copper-gold asset.
The Company also holds a 90% interest in the Limestone Well Vanadium -Titanium Project in
Western Australia.
Further information regarding FireFly Metals Ltd is available on the ASX platform (ASX: FFM) or the
Company’s website www.fireflymetals.com.au or SEDAR+ www.sedarplus.ca.
ABOUT BELLAVISTA RESOURCES LTD
Bellavista Resources Ltd (ASX: BVR) is an emerging mineral exploration company focused on
finding and acquiring world -class precious and base metal deposits in Tier 1 jurisdictions.
Bellavista recently acquired FireFly’s 7 0% interest in the high -grade Pickle Crow Gold Project in
Ontario, which has an inferred mineral resource of 2.8Moz at 7.2g/t gold, and other nearby highly
prospective exploration acreage with known mineralisation.
Bellavista also 100% owns the Brumby Base metal Project which is a large scale and highly
prospective mineral province in Western Australia capable of hosting giant to super -giant base
metal deposits, and battery mineral deposits.
Bellavista is led by mining industry veterans Mr Glenn Jardine and Mr Peter Canterbury who also
led the highly successful WA gold company De Grey Mining post discovery of the Hemi Gold deposit
until De Grey’s A$6 billion takeover by Northern Star Resources Ltd.
ASX: FFM | TSX: FFM
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COMPLIANCE STATEMENTS
Mineral Resource Estimate – Green Bay Project
The Mineral Resource Estimate for the Green Bay Project referred to in this announcement and set
out in Appendix A was first reported in the Company’s ASX announcement dated 18 November
2025, titled ‘Mineral Resource increases 51% to 1.4Mt of copper and 1.1Moz of gold’ and is also set out
in the Technical Report for the Ming Copper-Gold Mine, titled ‘National Instrument 43-101 Technical
Report, FireFly Metals Ltd, Green Bay Ming Mine Copper -Gold Project, Newfoundland’ with an issue
date of 1 December 2025 and a Mineral Resource effective date of 18 November 2025, available on
SEDAR+ at www.sedarplus.ca.
Mineral Resource Estimate – Little Deer
The Mineral Resource Estimate for Little Deer referred to in this announcement was first reported in
the Company’s ASX announcement dated 29 October 2024, titled ‘Resource Increases 42% to 1.2Mt
of contained metal at 2% Copper Eq’ and is also set out in th e Technical Report for the Little Deer
Copper Project, titled ‘Technical Report and Updated Mineral Resource Estimate of the Little Deer
Complex Copper Deposits, Newfoundland, Canada’ with an effective date of 26 June 2024,
available on SEDAR+ at www.sedarplus.ca.
Metal equivalents
Metal equivalents for the Mineral Resource Estimates have been calculated at a copper price of
US$8,750/t, gold price of US$2,500/oz and silver price of US$25/oz. Individual Mineral Resource
grades for the metals are set out in Appendix A of this announcem ent.
Copper equivalent was calculated based on the formula CuEq(%) = Cu(%) + (Au(g/t) x 0.82190) +
(Ag(g/t) x 0.00822).
Metallurgical factors have been applied to the metal equivalent calculation. Copper recovery used
was 95%. Historical production at the Ming Mine has a documented copper recovery of ~96%.
Precious metal (gold and silver) metallurgical recovery was assumed at 85% on the basis of
historical recoveries achieved at the Ming Mine in addition to historical metallurgical test work to
increase precious metal recoveries.
In the opinion of the Company, all elements included in the metal equivalent calculation have a
reasonable potential to be recovered and sold based on current market conditions, metallurgical
test work, the Company’s operational experience and, where relev ant, historical performance
achieved at the Green Bay project whilst in operation.
Original Announcements
FireFly confirms that it is not aware of any new information or data that materially affects the
information included in the original announcements referred to or cross -referenced in this
announcement and that, in the case of Mineral Resource Estimates, al l material assumptions and
technical parameters underpinning the Mineral Resource Estimates in the original announcements
continue to apply and have not materially changed. The Company confirms that the form and
context in which the Competent Persons’ and Qualified Persons’ findings are presented have not
been materially modified from the original market announcements.
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COMPETENT PERSON AND QUALIFIED PERSON STATEMENTS
All technical and scientific information in this announcement has been reviewed and approved by
Group Chief Geologist, Mr Juan Gutierrez BSc, Geology (Masters), Geostatistics (Postgraduate
Diploma), who is a Member and Chartered Professional of the Austral asian Institute of Mining and
Metallurgy and a Member of the Australian Institute of Geoscientists. Mr Gutierrez is a Competent
Person as defined in the JORC Code 2012 and a Qualified Person as defined in NI 43-101. Mr Gutierrez
is a full -time employee of, and holds securities in, the Company. Mr Gutierrez has sufficient
experience that is relevant to the style of mineralisation and type of deposit under consideration
and to the activity being undertaken to qualify as a Competent Person as defined in the JORC Code
2012 and a Qualified Person as defined in NI 43 -101. Mr Gutierrez has reviewed the contents of this
announcement and consents to the inclusion in this announcement of all matters based on his
information in the form and context in which they appear.
FORWARD-LOOKING STATEMENTS
This announcement may contain certain forward -looking statements and projections, including
statements regarding the Transaction, In-specie Distribution , FireFly’s plans, forecasts and
projections with respect to its mineral properties and programs, and anticipated timing, outcome
and effects of the Transaction and In -specie Distribution (including expected benefits to
shareholders of FireFly) . Forward-looking statements may be identified by the use of words such
as ‘may’, ‘might’, ‘could’, ‘would’, ‘will’, ‘expect’, ‘intend’, ‘believe’, ‘forecast’, ‘milestone’, ‘objective’,
‘predict’, ‘plan’, ‘scheduled’, ‘estimate’, ‘anticipate’, ‘continue’, or other similar words and may
include, without limitation, statements regarding plans, strategies and objectives.
Although the forward-looking statements contained in this announcement reflect management’s
current beliefs based upon information currently available to management and based upon what
management believes to be reasonable assumptions, such forward -looking statements and
projections are estimates only and should not be relied upon. They are not guarantees of future
performance and involve known and unknown risks, uncertainties and other factors, many of which
are beyond the control of the Company, which may include changes in commodity prices, foreign
exchange fluctuations, economic, social and political conditions, and changes to applicable
regulation, and those risks outlined in the Company’s public disclosures.
The forward-looking statements and projections are inherently uncertain and may therefore differ
materially from results ultimately achieved. For example, there can be no assurance that FireFly will
be able to confirm the presence of Mineral Resources or Ore Reserves, that FireFly’s plans for
development of its mineral properties will proceed, that any mineralisation will prove to be
economic, or that a mine will be successfully developed on any of FireFly’s mineral properties. The
performance of FireFly may be influenced by a number of factors which are outside of the control
of the Company, its directors, officers, employees and contractors. The Company does not make
any representations and provides no warranties concerning the accuracy of any forward -looking
statements or projections, and disclaims any obligation to update or revise any forward -looking
statements or projections based on new information, future events or circumstances or otherwise,
except to the extent required by applicable laws.
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APPENDIX A
Green Bay Copper-Gold Project Mineral Resource Estimate
Ming Deposit Mineral Resource Estimate
TONNES COPPER GOLD SILVER CuEq
(Mt) Grade Metal Grade Metal Grade Metal Grade
(%) (‘000 t) (g/t) (‘000 oz) (g/t) (‘000 oz) (%)
Measured 6.3 1.5 94 0.3 50 1.9 388 1.7
Indicated 41.2 1.7 708 0.4 488 3.2 4,320 2.1
TOTAL M&I 47.5 1.7 802 0.4 537 3.1 4,708 2.0
Inferred 23.1 2.0 456 0.7 553 5.9 4,379 2.6
Little Deer Mineral Resource Estimate
TONNES COPPER GOLD SILVER CuEq
(Mt) Grade Metal Grade Metal Grade Metal Grade
(%) (‘000 t) (g/t) (‘000 oz) (g/t) (‘000 oz) (%)
Measured - - - - - - - -
Indicated 2.9 2.1 62 0.1 9 3.4 320 2.3
TOTAL M&I 2.9 2.1 62 0.1 9 3.4 320 2.3
Inferred 6.2 1.8 110 0.1 10 2.2 430 1.8
GREEN BAY TOTAL MINERAL RESOURCE ESTIMATE
TONNES COPPER GOLD SILVER CuEq
(Mt) Grade Metal Grade Metal Grade Metal Grade
(%) (‘000 t) (g/t) (‘000 oz) (g/t) (‘000 oz) (%)
Measured 6.3 1.5 94 0.3 50 1.9 388 1.7
Indicated 44.1 1.7 769 0.4 496 3.3 4,638 2.1
TOTAL M&I 50.4 1.7 863 0.3 546 3.1 5,026 2.0
Inferred 29.3 1.9 566 0.6 563 5.1 4,810 2.5
1. FireFly Metals Ltd Mineral Resource Estimates for the Green Bay Copper -Gold Project, incorporating the
Ming Deposit and Little Deer Complex, are prepared and reported in accordance with the JORC Code 2012
and NI 43-101.
2. Mineral Resources have been reported at a 1.0% copper cut-off grade.
3. Metal equivalents for the Mineral Resource Estimates have been calculated at a copper price of
US$8,750/t, gold price of US$2,500/oz and silver price of US$25/oz. Metallurgical recoveries have been
set at 95% for copper and 85% for both gold and silver. T hese assumptions are made of the basis of
historical production at the Ming Mine and additional metallurgical test work. Copper equivalent was
calculated based on the formula: CuEq(%) = Cu(%) + (Au(g/t) x 0.82190) + (Ag(g/t) x 0.00822).
4. Totals may vary due to rounding.