Purpose
(1) This section allocates an appropriate * cost base to equity issued, or new debt owed, under the * arrangement, by a member of a * wholly - owned group to another member (the recipient ) of the group, if:
(a) the acquiring entity is a member of the group; and
(b) the cost base of an original interest was transferred or allocated under section 124 - 782 because the original interest holder is a * significant stakeholder or a * common stakeholder for the arrangement.
Allocation of cost base
(2) The first element of the * cost base of the equity or debt for the recipient is that part of the cost base of the original interest transferred or allocated under section 124 - 782 as:
(a) may be reasonably allocated to the equity or debt; and
(b) is not more than the * market value of the equity or debt just after the * arrangement was completed.