Canada Research | Page 64 of 87<strong>Uranium</strong>ARMZ Tax Battle with TRA. According to several news sources, the Tanzanian RevenueAuthority (TRA) is dem<strong>and</strong>ing ARMZ pay US$206 mln in capital gains taxes <strong>and</strong> stampduty following its US$1.04 bln acquisition of Mantra. Legal proceedings are on-going.We believe this situation is worth monitoring, given that:(i)(ii)(iii)According to Tanzania’s Public Corporations Accounts Committee, the countrymissed out on ~US$300 mln in potential tax revenue from the Bhati Airtel-ZainAfrica acquisition in 2010 (now a focus for the government’s opposition);The proposed 2012/2013 Tanzania budget (to be tabled in parliament in August2012) is reported to include a framework for the taxation of multinationalM&A;In a similar case, the tax authority of Ug<strong>and</strong>a ruled in November 2011 thatHeritage Oil must pay US$404 mln after its US$1.45 bln sale of Ug<strong>and</strong>an assetsto Tullow Oil in 2010.Although <strong>Uranium</strong> One maintains TRA’s case is without merit, the potential impact of anegative ruling would be very material to the company as, according to the put/callagreement, the total purchase amount is equal to what ARMZ paid (US$1.04 bln) plus,amongst other items, “expenses incurred by ARMZ in connection with the acquisition”;in our view, inclusion of this tax could further compel minority shareholders to vote ‘no’to acquiring the remainder of Mantra in June 2013.Is It Worth It? On balance, we view Mkuju as a world class deposit that is highly likely tobe developed; however, for <strong>Uranium</strong> One, the large up-front purchase/developmentcosts (requiring additional debt) <strong>and</strong> scalability risk suggest the company may seek toretain its 13.9% stake <strong>and</strong> not acquire the remainder. Based on our currentassumptions, our NAV estimate would be 21% higher if we assume <strong>Uranium</strong> One passeson the acquisition (see Exhibit 77). Our ‘without Mkuju’ scenario excludes the $0.9 blnpayment <strong>and</strong> 86.1% higher equity in Mkuju <strong>and</strong> the other Mantra assets.Exhibit 77: RJL NAV Estimate With <strong>and</strong> Without Mkuju River <strong>and</strong> Requisite DebtFunded NAV Valuation C$mln C$/afd.sh. Funded NAV (w/o Mkuju) C$mln C$/afd.sh. %Δ w/oCorporate Corporate MkujuWorking Capital (1Q12) 619,800 0.64 Working Capital (1Q12) 619,800 0.64 -Options & Warrants 40,273 0.04 Options & Warrants 40,273 0.04 -LT Liabilities (+PV of interest) (1,127,720) -1.17 LT Liabilities (+PV of interest) (1,011,023) -1.05 -10.3%Mantra Purchase (900,000) -0.93 Mantra Purchase 0 0.00 -100.0%Future Equity Raise 0 0.00 Future Equity Raise 0 0.00 -SG&A (NPV, 8%) (197,176) -0.20 SG&A (NPV, 8%) (197,176) -0.20 -(1,564,824) -1.62 (548,126) -0.57 -65.0%ProjectsProjectsAkdala (DCF, 8%) - 70% 480,467 0.50 Akdala (DCF, 8%) - 70% 480,467 0.50 -South Inkai (DCF, 8%) - 70% 1,171,961 1.21 South Inkai (DCF, 8%) - 70% 1,171,961 1.21 -Karatau (DCF, 8%) - 50% 760,004 0.79 Karatau (DCF, 8%) - 50% 760,004 0.79 -Kharasan (DCF, 8%) - 30% 311,973 0.32 Kharasan (DCF, 8%) - 30% 311,973 0.32 -Akbastau (DCF, 8%) - 50% 881,952 0.91 Akbastau (DCF, 8%) - 50% 881,952 0.91 -Zarechnoye (DCF, 8%) - 50% 420,073 0.43 Zarechnoye (DCF, 8%) - 50% 420,073 0.43 -Honeymoon (DCF, 8%) - 51% 56,476 0.06 Honeymoon (DCF, 8%) - 51% 56,476 0.06 -Willow Creek (DCF, 8%) - 100% 411,606 0.43 Willow Creek (DCF, 8%) - 100% 411,606 0.43 -Mkuju River (DCF, 8%) - 100% 339,722 0.35 Mkuju River (DCF, 8%) - 13.9% 47,221 0.05 -86.1%Other Mantra Assets (notional) 50,000 0.05 Other Mantra Assets (notional) 6,950 0.01 -86.1%4,884,234 5.05 4,548,683 4.70 -6.9%3,319,410 $3.43 4,000,557 $4.14 20.5%Source: Raymond James Ltd., <strong>Uranium</strong> One Inc.With that said, the upcoming DFS (3Q12E) should provide the requisite clarity on capex,opex, throughputs, <strong>and</strong> recoveries. We will also be looking for the change in Proven <strong>and</strong>Probable reserves (tonnages/grade), which should help quantify the economic impact ofthe lower cut-off grade in the November 2011 resource. Beyond movements in spoturanium prices, we view the study as the most important catalyst for the stock.Raymond James Ltd. | 2200 – 925 West Georgia Street | Vancouver BC Canada V6C 3L2
<strong>Uranium</strong> Canada Research | Page 65 of 87Other Potential ConcernsKazakh Exposure. In 2011A, 97.5% of production attributable to <strong>Uranium</strong> One came outof Kazakhstan <strong>and</strong> though diversification is a focus, with that number dropping to 68%by 2016E (RJL), our valuation is firmly Kazakh-focused, representing 82% of our projectNAV. Beyond obvious geopolitical risks (ranked 81 st of 93 jurisdictions in the FraserInstitute’s Policy Potential Index), recent inflation rates of 7% have impacted domesticproduction costs (outpacing exchange rates – thus, a negative).Acid Logistics. <strong>Uranium</strong> One states that for the past three years, constraints in thesupply of sulphuric acid – a critical component in preparing <strong>and</strong> producing fromKazakhstan’s low-salinity wellfields – have been ‘an issue,’ while Cameco admits Inkaiproduction for 2011A was below expectations due to brief interruptions in supply. Goingforward, we view acid logistics, particularly transportation <strong>and</strong> storage, as a key risk onplanned ramp-up, albeit, this risk is being eased with construction of storage facilities<strong>and</strong> SKZ-U’s US$199 mln, 500 ktpa sulphuric acid plant near Kharasan (start-up in2H12E; <strong>Uranium</strong> One owns 19%).Acid Consumption. For reference, acid consumption rates vary mine-by-mine, rangingfrom 58 kg acid/lb U3O8 produced at Akdala (as at September 2011) to 451 kg/lb atKharasan, located in the more carbonate-rich Syrdarya province. In May 2012, NuclearIntelligence reported average delivered acid costs of US$157/t in Kazakhstan; atZarechnoye, for example, this implies US$8.30/lb, or ~40% of 2011A cash costs(US$21/lb).Acid costs <strong>and</strong> utilization rates can thus strongly impact earnings <strong>and</strong>, in our view, are akey risk to <strong>Uranium</strong> One, given (i) existing deposits in the country are ageing, moving theminers into less attractive areas (on a uranium grade vs. carbonate content basis) <strong>and</strong>requiring more acid to maintain output levels, <strong>and</strong> (ii) most of the shallow, high-grade,low carbonate deposits in Chu-Sarysu province have already been exploited. IfKazakhstan continues to ramp production, country-wide acid dem<strong>and</strong> could outpacesupply, putting upward pressure on prices.Raymond James Ltd. | 2200 – 925 West Georgia Street | Vancouver BC Canada V6C 3L2