and/or nominee clause in NSW

Quick question,

If I sign a contract listed in 2 personal names with the intent of changing it to a company structure where neither party is a director, however both parties are shareholders. One as director of another company that holds 50% of the shares, the other as director of the corporate trustee for the family trust. I know that if we were both directors then it satisfies the OSR and we avoid double stamp duty, but how about the above scenario?

Cheers
Mick