Broadly speaking tax losses carried forward can only be utilised when at least 49% of shareholders who originally incurred that loss are still shareholders when the loss is claimed. Macquarie have about 42% if my memory serves me correctly, (after the sell-down in 2018). Its quite possible that the loss carried forward rules still applies as there may be more than 7% of other shareholders who carry the day.

When Macquarie continue their sell-down it is likely, (even if its only one more partial tranche), that the loss carried forward rules won't be met and OCA will have to pay more tax, lowering their net profit after tax. Most of these retirement companies pay very little tax but as OCA's primary business is care at present, (not development), this will hurt them and is another reason I don't hold. In time the dividends may be able to be partially imputed.