New South Wales Consolidated Acts(cf State Owned Corporations Act 1989 , section 20V)
(1) In this section:
"exempt matter" means:(a) the issue of shares of the Corporation or any of its subsidiaries to the constituent councils, or(b) the transfer of assets, rights or liabilities to the Corporation or any of its subsidiaries pursuant to a transfer order, or(c) giving effect to any of the above."tax" includes stamp duty and any other tax, duty, fee, levy or charge, but does not include tax-equivalents.
(2) Tax under a law of the State is not payable in relation to:(a) an exempt matter, or(b) anything done (including, for example, a transaction entered into or an instrument or document made, executed, lodged or given) because of, or for a purpose connected with or arising out of, an exempt matter.
(3) The Treasurer or a person authorised by the Treasurer may, by a written instrument, certify that:(a) a specified matter or thing is an exempt matter, or(b) a specified thing was done (including, for example, a transaction entered into or an instrument or document made, executed, lodged or given) because of, or for a purpose connected with or arising out of, a specified exempt matter.
(4) For all purposes and in all proceedings, a certificate under this section is conclusive evidence of the matters certified, except so far as the contrary is established.