COPY OF FINAL PROSPECTUS - Mirabela Nickel

The Ponto Novo project area consists of a four kilometre by one kilometre ridge of serpentinite that
management believes could represent similar geology to the Santa Rita mafic-ultramafic intrusion. The ridge is
surrounded by alluvial sands at surface. The regional geological context of Ponto Novo is consistent with that
found at the Santa Rita deposit and as such management believes it may represent an extension of the same
structural margin environment.
Exploration of the Ponto Novo project area to date however has been hampered by the lateritic cap rock
over the intrusion that conceals the underlying geology and complicates geochemical sampling. The Company
intends to undertake an IP geophysics program to assess the potential for Santa Rita type mineralization and a
possible nickel laterite resource, assess the extent of alluvial cover in the area and identify undercover geology.
Araguacema
The Araguaçema copper project area is located close to the Araguaia River, 200 kilometres north-west of
Palmas, the capital of Tocantins state. The Company acquired its interest in the Araguacema property because
previous explorers identified a copper sulphide intersection of six metres at a grading of 1.26% copper and a
copper oxide intersection of 20 metres at a grading of 0.71% copper in a trench, hosted by basalt and iron-rich
exhalative rocks. Such a geological environment is generally considered prospective for volcanogenic massive
sulphide deposits, which can host copper, lead and zinc mineralizations.
CANADIAN FEDERAL INCOME TAX CONSIDERATIONS
FOR CANADIAN SHAREHOLDERS OF MIRABELA
The following is a general summary of the principal Canadian federal income tax considerations generally
applicable to purchasers of Shares who, for purposes of the Income Tax Act (Canada) (the ‘‘Tax Act’’) and for
purposes of the Australia-Canada Income Tax Convention, at all relevant times, is or is deemed to be resident in
Canada, will hold the Shares issued under this prospectus as capital property and deals at arm’s length with and
is not affiliated with Mirabela (a ‘‘Holder’’). Generally, the Shares will be considered to be capital property to a
Holder provided that the Holder does not hold the Shares in the course of carrying on a business of buying and
selling securities and has not acquired the Shares as an adventure in the nature of trade. Under the Tax Act,
shares, including the Shares, acquired by certain ‘‘financial institutions’’ (as defined in subsection 142.2(1) of the
Tax Act) will generally not be held as capital property by such holders and will be subject to special
‘‘mark-to-market’’ rules contained in the Tax Act. This summary does not take into account these special rules,
and prospective purchasers to which these special rules may be relevant should consult their own tax advisors.
This summary does not apply where the Company would be a ‘‘foreign affiliate’’ of the prospective purchaser for
purposes of the Tax Act. This summary does not apply to a prospective purchaser of an interest which would be a
‘‘tax shelter investment’’ as defined in the Tax Act. Such prospective purchasers should consult their own
tax advisors.
This summary is of general nature only and is not intended to be, nor should it be construed to be, legal or
tax advice to any particular investor. This summary is not exhaustive of all Canadian federal income tax
considerations. There may also be tax implementations for investors under the laws of Australia or the laws of
any other jurisdiction in which the investor resides or to which the investor is subject, which are not addressed by
this summary. Accordingly, prospective purchasers are urged to consult their own tax advisors with respect to
their particular circumstances.
This summary is based on the current provisions of the Tax Act, the regulations thereunder, all specific
proposals to amend the Tax Act and the regulations publicly announced by or on behalf of the Minister of
Finance (Canada) prior to the date hereof (the ‘‘Proposals’’) and the current administrative policies and
assessing practices of the Canada Revenue Agency (the ‘‘CRA’’) publicly available prior to the date hereof. No
assurance can be given that the Proposals will be enacted in their current form or at all. This summary does not
otherwise take into account any changes in law or in the administrative policies or assessing practices of the
CRA, whether by legislative, governmental or judicial decision or action, nor does it take into account or
consider any provincial, territorial or foreign income tax considerations. The provisions of provincial income tax
legislation vary from province to province in Canada and in some cases differ from federal income tax
legislation.
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