One large element of that obstacle crumbled in 2018 and 2020 when various tax authorities dealt with the issue of BHP using the Singapore marketing hub as a conduit through which it sold its product.
The other troublesome impediment to BHP cleaning up its capital structure was the treatment of tax losses from NSW coal mines. As part of a corporate tidy up in the lead up to an asset sale, BHP announced on Wednesday it had written down the value of these tax losses.
There are certain to be other complicating factors in such a major overhaul in BHP’s corporate structure, but with both the tax issues resolved, BHP’s largest impediment now is the will to proceed.
When Elliott began agitating for listing unification of BHP Group Ltd and BHP Plc back in 2017, BHP appeared deeply disinclined to entertain the proposition.
Elliott’s lobbying effort was then part of a far larger push for the resource conglomerate to sell assets, reallocate capital and apply more rigour to acquisitions. It argued that the unconventional onshore oil/gas shale assets should be divested as a priority and the offshore conventional oil assets should be next.