Calculation of Base Cost of Fyffes shares and Blackrock International Land shares

Following the disposal by Fyffes of part of its undertaking to Blackrock International Land plc (Blackrock) in exchange for the issue of Blackrock shares to the shareholders in Fyffes, the base cost of Fyffes shares must be apportioned accordingly.

Apportionment Of Base Cost

For the purpose of computing a gain or loss accruing from the disposal of any part of the “new holding”, within the meaning of Section 584(1) TCA 1997, the total cost of the "new holding" is apportioned on the basis of the market values of the Fyffes shares and the Blackrock shares after the demerger.

Pursuant to the disposal each Fyffes shareholder received one share in Blackrock for each Fyffes share held prior to the transaction. In accordance with the provisions of the Capital Gains Tax Acts, the market value of the Fyffes shares and the Blackrock shares, following the demerger, are as follows:

Fyffes: €1.47

Blackrock: €0.43

To illustrate the mechanism for determining the base cost of the shares in the event of a future disposal, assume Fyffes shares were acquired before the demerger for €2.

Revenue will accept that the base cost to be used on the disposal of Fyffes shares is as follows:

Fyffes:

Revenue will accept that the base cost to be used on the disposal of Blackrock shares is as follows:

Blackrock:

The percentage split of the base cost between Fyffes and Blackrock is therefore:

Fyffes:

Blackrock:

Any Fyffes or Blackrock shares acquired after the demerger are not affected.