Mr. Steve Parsons reports

ATO CLASS RULING FOR FIREFLY'S IN-SPECIE DISTRIBUTION OF BELLAVISTA SHARES

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 Metals Ltd.'s share capital effected by way of the in specie distribution of shares in Bellavista Resources Ltd. to eligible Firefly shareholders.

The in specie distribution completed on May 11, 2026 (payment date), and involved the transfer to eligible Firefly shareholders of 60 million ordinary shares in Bellavista that were received by Firefly on April 29, 2026, at completion of the transaction announced on Feb. 2, 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 May 4, 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 March 23, 2026, 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. The capital return is not a dividend, 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). 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.

The table below summarizes the key Australian income tax outcomes for class ruling shareholders confirmed by the ATO class ruling.

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 the ATO class ruling, which can be accessed from the ATO website.

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 May 11, 2026, eligible Firefly shareholders were transferred one 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 dispatched on May 11, 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 54.6975 cents for each Bellavista share they would have been entitled to be distributed had they been eligible Firefly shareholders. Payment to ineligible Firefly shareholders was dispatched on May 27, 2026.