Class Ruling CR 2026/26

What this ruling is about: 1. This Ruling sets out the income tax consequences for employees or non-executive directors of Robex Resources Inc., or one of its subsidiaries (Robex), who held certain awards in Robex when Predictive Discovery Limited (PDI) acquired Robex on 15 April 2026 (Effective Date), in connection with a plan of arrangement (PoA). 2. Details of this scheme are set out in paragraphs 14 to 33 of this Ruling. 3. All legislative references in this Ruling are to the Income Tax Assessment Act 1997, unless otherwise indicated. Who this Ruling applies to 4. This Ruling applies to you if you are a resident of Australia as defined in subsection 6(1) of the Income Tax Assessment Act 1936 and you: 5. This Ruling does not apply to anyone who is subject to the taxation of financial arrangements rules in Division 230 in relation to the scheme outlined in paragraphs 14 to 33 of this Ruling. Note: Division 230 will not apply to individuals unless they have made an election for it to apply. When this Ruling applies 6. This Ruling applies from 1 July 2025 to 30 June 2026. Options and Performance Share Units under an employee share scheme 7. The Options and PSUs you acquired prior to the Effective Date were ESS interests acquired under an employee share scheme (paragraph 83A-10(1)(b) and subsection 83A-10(2)). 8. The Options and PSUs you acquired pursuant to the PoA are ESS interests acquired under an employee share scheme (subsections 83A-10(1) and (2)). 9. Subdivision 83A-C applied to the Options and PSUs you acquired prior to the Effective Date and to the Options and PSUs you acquired pursuant to the PoA (subsection 83A-105(1)). New ESS interests are a continuation of old ESS interests 10. The Options you acquired pursuant to the PoA are treated as a continuation of the Options you acquired prior to the Effective Date for the purposes of Division 83A (subsection 83A-130). 11. The PSUs that you acquired pursuant to the PoA are treated as a continuation of the PSUs you acquired prior to the Effective Date for the purposes of Division 83A (subsection 83A-130). 12. Therefore, the disposal of your Options and PSUs you acquired prior to the Effective Date will not result in an ESS deferred taxing point occurring within the meaning of section 83A-120. Continuation of employment 13. Your employment with PDI, or one of its subsidiaries, after the Effective Date is treated as a continuation of your employment in respect of which you acquired Options and PSUs prior to the Effective Date for the purposes of Division 83A (subsection 83A-130(6)). 14. The following description of the scheme is based on information provided by the applicant. If the scheme is not carried out as described, this Ruling cannot be relied upon. Background 15. Robex is a Canadian public corporation that was incorporated in Quebec on 14 June 1985. 16. Robex's subsidiaries are engaged in mining exploration and the operation of gold mines in West Africa, specifically in Mali and Guinea. 17. Robex is a public company that has issued shares that have been listed on the TSX Venture Exchange (TSXV) since 2022. 18. Robex operated an employee share scheme by providing employees with Options and PSUs issued under the Option Plan and Omnibus Plan respectively. 19. As at 13 November 2025, Robex had issued 6,400,000 Options and 5,150,000 PSUs. Robex Resources Inc. Share Purchase Option Plan 20. Key features of the Option plan: Omnibus Equity Incentive Plan 21. Key features of Omnibus Plan: Predictive Discovery Limited 22. PDI is an Australian public company that was incorporated on 22 August 2007 and has been listed on the Australian Securities Exchange (ASX) since May 2010 (under ASX code 'PDI'). 23. PDI is primarily engaged in mineral exploration with a focus on developing economic gold reserves. PDI primarily operates in Guinea, West Africa. Plan of arrangement 24. On 6 October 2025, Robex and PDI announced to the TSXV and ASX respectively that they had entered into an arrangement agreement (Arrangement Agreement) for a 'merger of equals' by way of a Canadian court-approved PoA under Quebec corporate law. 25. Under the terms of the PoA, PDI, via a newly incorporated Canadian subsidiary, acquired 100% of the issued shares in Robex in exchange for newly issued PDI shares. 26. The Arrangement Agreement was agreed and executed by Robex and PDI on 5 October 2025 and announced to the ASX and TSXV on 6 October 2025. The Arrangement Agreement and the PoA were later amended on 12 December 2025 to primarily change the exchange ratio to be used for the exchange of Robex shares for PDI shares (Exchange Ratio). 27. The PoA applied to all holders of Robex shares equally on the same terms. 28. The PoA was approved by Robex shareholders at a shareholder meeting on 30 December 2025. Court approval for the PoA was granted on 13 January 2026. 29. PDI and Robex announced to the market on 8 April 2026 that the conditions precedent to the transaction had been satisfied. 30. All of the Robex shares on issue were acquired by PDI, via its newly incorporated Canadian subsidiary, on the Effective Date. 31. For participants who held Options and PSUs granted under the Option Plan and Omnibus Plan that remained outstanding immediately prior to the Effective Date, the PoA resulted in those Options and PSU's being replaced with Options and PSU's respectively pursuant to the terms outlined in the PoA, which among other things, continue to be governed by the Option Plan and Omnibus Plan respectively, such as the performance and vesting conditions. 32. Other key features of the replacement Options are: 33. Other key features of the replacement PSUs are: Commissioner of Taxation 20 May 2026 © AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).

Class of entities or scheme: 7. The Options and PSUs you acquired prior to the Effective Date were ESS interests acquired under an employee share scheme (paragraph 83A-10(1)(b) and subsection 83A-10(2)). 8. The Options and PSUs you acquired pursuant to the PoA are ESS interests acquired under an employee share scheme (subsections 83A-10(1) and (2)). 9. Subdivision 83A-C applied to the Options and PSUs you acquired prior to the Effective Date and to the Options and PSUs you acquired pursuant to the PoA (subsection 83A-105(1)). | New ESS interests are a continuation of old ESS interests: 10. The Options you acquired pursuant to the PoA are treated as a continuation of the Options you acquired prior to the Effective Date for the purposes of Division 83A (subsection 83A-130). 11. The PSUs that you acquired pursuant to the PoA are treated as a continuation of the PSUs you acquired prior to the Effective Date for the purposes of Division 83A (subsection 83A-130). 12. Therefore, the disposal of your Options and PSUs you acquired prior to the Effective Date will not result in an ESS deferred taxing point occurring within the meaning of section 83A-120. | Continuation of employment: 13. Your employment with PDI, or one of its subsidiaries, after the Effective Date is treated as a continuation of your employment in respect of which you acquired Options and PSUs prior to the Effective Date for the purposes of Division 83A (subsection 83A-130(6)). 14. The following description of the scheme is based on information provided by the applicant. If the scheme is not carried out as described, this Ruling cannot be relied upon. | Background: 15. Robex is a Canadian public corporation that was incorporated in Quebec on 14 June 1985. 16. Robex's subsidiaries are engaged in mining exploration and the operation of gold mines in West Africa, specifically in Mali and Guinea. 17. Robex is a public company that has issued shares that have been listed on the TSX Venture Exchange (TSXV) since 2022. 18. Robex operated an employee share scheme by providing employees with Options and PSUs issued under the Option Plan and Omnibus Plan respectively. 19. As at 13 November 2025, Robex had issued 6,400,000 Options and 5,150,000 PSUs. | Robex Resources Inc. Share Purchase Option Plan: 20. Key features of the Option plan: | Omnibus Equity Incentive Plan: 21. Key features of Omnibus Plan: | Predictive Discovery Limited: 22. PDI is an Australian public company that was incorporated on 22 August 2007 and has been listed on the Australian Securities Exchange (ASX) since May 2010 (under ASX code 'PDI'). 23. PDI is primarily engaged in mineral exploration with a focus on developing economic gold reserves. PDI primarily operates in Guinea, West Africa. | Plan of arrangement: 24. On 6 October 2025, Robex and PDI announced to the TSXV and ASX respectively that they had entered into an arrangement agreement (Arrangement Agreement) for a 'merger of equals' by way of a Canadian court-approved PoA under Quebec corporate law. 25. Under the terms of the PoA, PDI, via a newly incorporated Canadian subsidiary, acquired 100% of the issued shares in Robex in exchange for newly issued PDI shares. 26. The Arrangement Agreement was agreed and executed by Robex and PDI on 5 October 2025 and announced to the ASX and TSXV on 6 October 2025. The Arrangement Agreement and the PoA were later amended on 12 December 2025 to primarily change the exchange ratio to be used for the exchange of Robex shares for PDI shares (Exchange Ratio). 27. The PoA applied to all holders of Robex shares equally on the same terms. 28. The PoA was approved by Robex shareholders at a shareholder meeting on 30 December 2025. Court approval for the PoA was granted on 13 January 2026. 29. PDI and Robex announced to the market on 8 April 2026 that the conditions precedent to the transaction had been satisfied. 30. All of the Robex shares on issue were acquired by PDI, via its newly incorporated Canadian subsidiary, on the Effective Date. 31. For participants who held Options and PSUs granted under the Option Plan and Omnibus Plan that remained outstanding immediately prior to the Effective Date, the PoA resulted in those Options and PSU's being replaced with Options and PSU's respectively pursuant to the terms outlined in the PoA, which among other things, continue to be governed by the Option Plan and Omnibus Plan respectively, such as the performance and vesting conditions. 32. Other key features of the replacement Options are: 33. Other key features of the replacement PSUs are: Commissioner of Taxation 20 May 2026 © AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).

Ruling: 1. This Ruling sets out the income tax consequences for employees or non-executive directors of Robex Resources Inc., or one of its subsidiaries (Robex), who held certain awards in Robex when Predictive Discovery Limited (PDI) acquired Robex on 15 April 2026 (Effective Date), in connection with a plan of arrangement (PoA). 2. Details of this scheme are set out in paragraphs 14 to 33 of this Ruling. 3. All legislative references in this Ruling are to the Income Tax Assessment Act 1997, unless otherwise indicated. | Who this Ruling applies to: 4. This Ruling applies to you if you are a resident of Australia as defined in subsection 6(1) of the Income Tax Assessment Act 1936 and you: 5. This Ruling does not apply to anyone who is subject to the taxation of financial arrangements rules in Division 230 in relation to the scheme outlined in paragraphs 14 to 33 of this Ruling. Note: Division 230 will not apply to individuals unless they have made an election for it to apply. | When this Ruling applies: 6. This Ruling applies from 1 July 2025 to 30 June 2026. | Options and Performance Share Units under an employee share scheme: 7. The Options and PSUs you acquired prior to the Effective Date were ESS interests acquired under an employee share scheme (paragraph 83A-10(1)(b) and subsection 83A-10(2)). 8. The Options and PSUs you acquired pursuant to the PoA are ESS interests acquired under an employee share scheme (subsections 83A-10(1) and (2)). 9. Subdivision 83A-C applied to the Options and PSUs you acquired prior to the Effective Date and to the Options and PSUs you acquired pursuant to the PoA (subsection 83A-105(1)). | New ESS interests are a continuation of old ESS interests: 10. The Options you acquired pursuant to the PoA are treated as a continuation of the Options you acquired prior to the Effective Date for the purposes of Division 83A (subsection 83A-130). 11. The PSUs that you acquired pursuant to the PoA are treated as a continuation of the PSUs you acquired prior to the Effective Date for the purposes of Division 83A (subsection 83A-130). 12. Therefore, the disposal of your Options and PSUs you acquired prior to the Effective Date will not result in an ESS deferred taxing point occurring within the meaning of section 83A-120. | Continuation of employment: 13. Your employment with PDI, or one of its subsidiaries, after the Effective Date is treated as a continuation of your employment in respect of which you acquired Options and PSUs prior to the Effective Date for the purposes of Division 83A (subsection 83A-130(6)). 14. The following description of the scheme is based on information provided by the applicant. If the scheme is not carried out as described, this Ruling cannot be relied upon. | Background: 15. Robex is a Canadian public corporation that was incorporated in Quebec on 14 June 1985. 16. Robex's subsidiaries are engaged in mining exploration and the operation of gold mines in West Africa, specifically in Mali and Guinea. 17. Robex is a public company that has issued shares that have been listed on the TSX Venture Exchange (TSXV) since 2022. 18. Robex operated an employee share scheme by providing employees with Options and PSUs issued under the Option Plan and Omnibus Plan respectively. 19. As at 13 November 2025, Robex had issued 6,400,000 Options and 5,150,000 PSUs. | Robex Resources Inc. Share Purchase Option Plan: 20. Key features of the Option plan: | Omnibus Equity Incentive Plan: 21. Key features of Omnibus Plan: | Predictive Discovery Limited: 22. PDI is an Australian public company that was incorporated on 22 August 2007 and has been listed on the Australian Securities Exchange (ASX) since May 2010 (under ASX code 'PDI'). 23. PDI is primarily engaged in mineral exploration with a focus on developing economic gold reserves. PDI primarily operates in Guinea, West Africa. | Plan of arrangement: 24. On 6 October 2025, Robex and PDI announced to the TSXV and ASX respectively that they had entered into an arrangement agreement (Arrangement Agreement) for a 'merger of equals' by way of a Canadian court-approved PoA under Quebec corporate law. 25. Under the terms of the PoA, PDI, via a newly incorporated Canadian subsidiary, acquired 100% of the issued shares in Robex in exchange for newly issued PDI shares. 26. The Arrangement Agreement was agreed and executed by Robex and PDI on 5 October 2025 and announced to the ASX and TSXV on 6 October 2025. The Arrangement Agreement and the PoA were later amended on 12 December 2025 to primarily change the exchange ratio to be used for the exchange of Robex shares for PDI shares (Exchange Ratio). 27. The PoA applied to all holders of Robex shares equally on the same terms. 28. The PoA was approved by Robex shareholders at a shareholder meeting on 30 December 2025. Court approval for the PoA was granted on 13 January 2026. 29. PDI and Robex announced to the market on 8 April 2026 that the conditions precedent to the transaction had been satisfied. 30. All of the Robex shares on issue were acquired by PDI, via its newly incorporated Canadian subsidiary, on the Effective Date. 31. For participants who held Options and PSUs granted under the Option Plan and Omnibus Plan that remained outstanding immediately prior to the Effective Date, the PoA resulted in those Options and PSU's being replaced with Options and PSU's respectively pursuant to the terms outlined in the PoA, which among other things, continue to be governed by the Option Plan and Omnibus Plan respectively, such as the performance and vesting conditions. 32. Other key features of the replacement Options are: 33. Other key features of the replacement PSUs are: Commissioner of Taxation 20 May 2026 © AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).




What this Ruling is about | If this Ruling applies to you, and you correctly rely on it, we will apply the law to you in the way set out in this Ruling. That is, you will not pay any more tax or penalties or interest in respect of the matters covered by this Ruling.


Legislative references: ITAA 1936 6(1) ITAA 1997 Div 83A ITAA 1997 83A-10(1) ITAA 1997 83A-10(1)(b) ITAA 1997 83A-10(2) ITAA 1997 Subdiv 83A-C ITAA 1997 83A-105(1) ITAA 1997 83A-120 ITAA 1997 83A-130 ITAA 1997 83A-130(6) ITAA 1997 Div 230