(1) This section has effect for the purposes of the Tax Act if:
(a) shares in the transferring body are issued under subsection 11(3) of this Act to the holding company; and
(b) the holding company was dormant, within the meaning of Part VI of the Companies Act 1981 , throughout the period beginning when it was incorporated and ending immediately before the shares are so issued.
(2) For the purposes of determining whether the holding company is a group company in relation to a body corporate in relation to a period, the holding company shall be deemed not to have been in existence at any time during the period referred to in paragraph ( 1)(b).