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    Ineligible transactions

    The following transactions are not eligible for demerger relief:

    • share buy-backs (that is, off-market purchases under Division 16K of Part III of the Income Tax Assessment Act 1936)
    • situations where any owner of the head entity can get rollover relief from other provisions of the tax law for all capital gains tax (CGT) events that happen to their ownership interests under the demerger.
      Last modified: 03 Feb 2016QC 17023