If the ATO safe harbour rules are unavailable for your Employee Share Scheme, you will likely need a valuation of the options or shares that are to be issued. This involves an assessment of the business value and equity (share) value of your company. This all needs to be done consistent with the ATO Market Valuation Guidelines. To understand what goes into such a valuation, a sample report from a recent engagement is available here (names and details changed for confidentiality reasons).
We would be happy to discuss your needs and engage with your tax adviser. You can contact Michael Churchill or Dominic Churchill on +61 3 9013 6330 or email mchurchill@peloton.group or dchurchill@peloton.group.