If the ATO tell you that there is no CGT event when exercising...

If the ATO tell you that there is no CGT event when exercising your options it will mean that your effective date for CGT purposes is the date of purchase of options NOT the conversion date.

If this is not the case, THEN there would be a CGT event in which case the date starts at conversion. HOWEVER it would then mean that you need to declare a gain/loss at that stage.

I am pretty certain that your original thoughts are correct but it is always best to consult a qualified person in a case like this.

And of course I hope you will need to declare a capital gain in the end ;)

W2