Duties Act 2001

A corporate reconstruction happens if—

through a transaction or series of transactions, property is transferred, or agreed to be transferred, for the purpose of changing a corporate structure to make internal adjustments to corporate arrangements; and

the transaction or each transaction is necessary to give effect to the purpose and is not undertaken for any other purpose; and

the transfer, or agreement for the transfer, of the property is not part of an arrangement under which any company involved with any of the transactions will or may cease, at any time, to belong to the same corporate group other than in the circumstances mentioned in section 412(4).

For subsection (1)(b), a transaction that is 1 in a series of transactions is taken to be necessary to give effect to the purpose if it is necessary for an exemption to apply to the transaction.