For the purposes of the 1997 Tax Act, if any of the following results in the acquisition of a CGT asset, then the first element of the cost base of the asset is taken to be nil:
(a) the issue of shares to a person under section 21;
(b) the issue of shares to a person in accordance with HoldCo's constitution, where the issue is certified under section 36;
(c) a certified demerger matter.
Note: Section 110 - 25 of the 1997 Tax Act defines the elements of the cost base.