The Newco shares will be pure Profit, i.e if you get R100,000 worth of Newco, that will be applicable to CGT as if you sold NPN.
That is my understanding and I based my decision on that.
In terms of the proposal, shareholders will receive new Naspers M-shares as a capitalisation issue, which do not have immediate tax liabilities. Capitalisation shares are exempt from dividend tax, but CGT become payable whenever the shares are sold
The circular states that the initial cost of these shares for the purposes of CGT will be deemed to be nil, meaning that the full value of the shares will attract CGT whenever a shareholder sells them. The M-shares are automatically replaced by NewCo shares, which is effectively seen as two separate transactions: the sale of M-shares and the purchase of NewCo shares.