17   State taxation

(1)  In this section:

exempt matter means:

(a)  the formation of, or the acquisition of shares in, a company in anticipation of the establishment of a company SOC, or

(b)  the registration of such a company, or

(c)  the issue or transfer of shares of a company SOC or any of its subsidiaries to eligible Ministers, or

(d)  the transfer of assets, rights or liabilities to a company SOC or any of its subsidiaries from the State, any authority of the State or any subsidiary of an authority of the State, or

(e)  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 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.