General value shifting regime (GVSR)



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If you own shares in a company or units (or other fixed interests) in a trust, you may be affected by value shifting rules. The value shifting rules may apply to you if:

  • you have interests in a company or trust in which equity or loan interests have been issued or bought back at other than market value, or varied such that the values of some interests have increased while others have decreased (direct value shifts on interests), or
  • you have interests in an entity whose dealings (such as providing loans or other services, or transferring assets) with another entity are neither at market value nor arm's length and both entities are under the same control or ownership (indirect value shifting).

For more information on whether the GVSR rules apply to you, refer to the publication General value shifting regime in brief. For detailed information on the operation of the rules, refer to the Guide to the general value shifting regime on our website at

Last modified: 04 Mar 2016QC 27527