(1)  The Commissioner may revoke an exemption granted under this Part in relation to a transaction if –

(a) any member of the relevant corporate group involved in the transaction in respect of which the exemption was granted does not remain a member of the group for a period of at least 12 months commencing immediately after the day on which the transaction occurred; or

(b) the exemption was granted based on false or misleading information provided to the Commissioner by the corporate group or a member of the group.

(2)  Subsection (1)(a) does not apply if the Commissioner is satisfied that a member of the relevant corporate group involved in the transaction (being a transaction within the meaning of section 226E ) in respect of which the exemption was granted ceases to be a member of the group by virtue of –

(a) a public float that occurred within 12 months after the day on which the transaction occurred; or

(b) the shares or units of the member being unstapled (so that the shares or units may be traded separately from the shares or units in any of the shares or units of the other members) to enable the member's liquidation, deregistration, dissolution or, in the case of a unit trust scheme, winding-up; or

(c) its liquidation, deregistration or, in the case of a unit trust scheme, winding-up.

(3)  The Commissioner must assess the duty payable on a corporate reconstruction transaction, or corporate consolidation transaction, for which an exemption is revoked.

(4)  Each member (at the date of the transaction) of the corporate group to which the transaction relates is jointly and severally liable to pay the duty chargeable on the transaction.

(5)  In this section –

public float means a share float or an offer of units to create a public unit trust scheme –

(a) the shares or units of which are quoted on the ASX or a recognised stock exchange and are offered to the public generally; and

(b) of which the issue of the shares or units to the public does not give any person and their related persons (other than the corporate entity that floated the shares or units) a combined beneficial interest in the floated entity greater than 20%; and

(c) that is not part of a scheme for the purpose of minimising duty otherwise payable under this Act.