Section 56BC(7)
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(7) If the option property is conveyed to a third person, the reduction of ad valorem duty available to the first person under subsection (6) will only extend to the third person if the Commissioner is satisfied:
(a) that:
(i) the first person was, at the time of the transfer of the call option, acting as agent of the third person; or
(ii) the third person is a corporation or the trustee of a trust that the first person was, at the time of the transfer of the call option, in the process of incorporating, establishing or acquiring; and
(b) that there has been no sub-sale or other dutiable dealing with the option property between the time of the transfer of the call option and the conveyance to the third person.