Co is a public company that employs Joe. On 1 December 2020, Joe was provided, for no consideration, rights to acquire 10,000 shares in C Co under an ESS for $1 per share. At that time, the rights were valued at $3,000. The terms of the ESS require Joe to work for C Co until 1 December 2023, otherwise the rights will be forfeited. Joe satisfied this requirement and the rights are valued at $9,000 on 1 December 2023. How does div 83A apply to this arrangement