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 holder ) of the group, if:
(a) an acquiring entity is a member of the group; and
(b) the cost base of the acquiring entity for a qualifying interest was worked out under section 124 - 784B.
Allocation of cost base
(2) The first element of the * cost base of the equity or debt for the holder is that part of the cost base of the qualifying interest worked out under section 124 - 784B 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 at the completion time.