INCOME TAX ASSESSMENT ACT 1936
(a) all membership rights in both companies are extinguished; and
(b) shares in the mutual insurance company and the mutual affiliate company are issued to another company (the holding company ); and
(c) shares (the ordinary shares ) of only one class in:
(i) the holding company; or
(ii) another company (the ultimate holding company ) of which the holding company is a wholly-owned subsidiary, either directly or through one or more other wholly-owned subsidiaries (each of which is an interposed holding company );
(iii) issued, at the election of each person in the policyholder/member group to the person or to a trustee to sell on behalf of the person; or
(iv) issued to a trustee, at the election of each person in the policyholder/member group, to distribute to the person or to sell on behalf of the person; and
(d) the trustee sells the ordinary shares and distributes the proceeds of the sale to the person, or distributes the ordinary shares to the person; and
(e) the ordinary shares are listed within the listing period.
Other things may also happen in connection with the implementation of the demutualisation.121AL(2) [Diagram of transactions]
The following diagram shows the main events, where this demutualisation method is used involving an election covered by subparagraph (1)(c)(iv).