As stated in ASIC Regulatory Guide (RG) 261 and s738H of the Corporations Act 2001, “not being listed on a financial market in Australia or overseas (including its related parties)” is among the requirements for company eligibility to make a Crowd-sourced funding (CSF) offer.
Ms. Apple holds 15% of X Pty Ltd., 100% of Y Ltd., and 15% of Z Pty Ltd.
Square Co Ltd holds 43% of X Pty Ltd., the rest (%42) of the company shares is held by Mr. Apple., the husband of Ms. Apple.
Finally, Circle Co Ltd. holds 85% of Z Pty Ltd.
Question 1
When assessing the CSF eligibility of Y Ltd, are Circle Co Ltd. or Square Co Ltd. related body corporates of Y Ltd.? Please state your reasons.

Question 2
When assessing the CSF eligibility of Y Ltd in making Crowd-sourced funding (CSF) offers, would it be accurate to say Ms. and Mr. Apple are related parties under RG 261? Please state your reasons.