I don't know. There are some really misleading articles out there about the rollover relief Afterpay was seeking from the ATO about this deal - and I think a lot are wrong so it would be best to consult a registered tax accountant and ask them.
What I do know is that if you take the CDI option and automatically let your ASX:APT shares become ASX:SQ2 then that won't be a CGT event and no you won't need to pay CGT on that transaction... but when you sell the ASX:SQ2 shares you will certainly be attracting CGT then.
