It is also unclear whether divestment by sale of shares to the public through an initial public offering (IPO) of at least 51% of the shares in the IUP holder on the Jakarta Stock Exchange would satisfy the divestment requirements under GR 24/2012. Only a handful of the top 10 coal producers will be affected by this new divestment requirement. A number of foreign investors have taken minority interests with an offtake arrangement over a higher proportion of the coal produced. With this new divestment requirement, this trend may continue.
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