Capital Gains Tax consequences of a demerger for a demerging entity

the Demerged Company doesn't have ownership interests in the taxpayer (subsection 125-65(3) of the ITAA 1997); and 2. there is no other company that is capable of being a 'head entity' having the Demerged Company as a 'demerger subsidiary' (subsection 125-65(4) of the ITAA 1997).