Good question.
I am leaning toward it being a capital gain..... there are more details from page 182 in the Scheme booklet onwards regarding tax. Am not sure we are allowed to copy and disseminate any parts of the booklet. So I'll just point you to the section where it uses the "cash consideration" in the formula as part of a CGT rollover to RMS, which then suggests to me that it is a capital gain. They have also said they are seeking an ATO ruling on aspects of the taxation, so that might affect the answer to your question down the track.
Ann: Court Approves Convening of Scheme Meeting, page-51
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