Axel Ltd is a company incorporated in Australia whose business is building construction, property development and farming in New Zealand. In $2021$Axel Ltd entered into a $50/50$

$$joint venture agreement with an Australian incorporated

agricultural finance company called Greedy Ltd$.$Each joint venture partner agreed to take up $200,000$ $$1$shares in an Australian incorporated farming company called Black Pty Ltd

$,$which owned the farmland in question.

Axel intended to hold its interest in Black Pty Ltd as a long

$-$term investment. Owing to unforeseen circumstances, farming proved to be unprofitable and there was a zoning change in $2023$ whereby properties in the area could only be disposed of in $25$ hectare parcels. Black Pty Ltd borrowed $$1$

$$million in December $2023$to hire lawyers and surveyors to divide up the property. In January $2024$ Black had sold all the $25$

$-$hectare parcels to a single buyer for a profit of $ $5$

$$million and invested the proceeds to buy more land. Axel Ltd and Greedy Ltd then sold their interests in Black Pty Ltd for

$$10$million in June $2024.$

Explain the income tax implications of the above transactions for Axel and Black.