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Control threshold tests

Last updated 19 July 2017

Control threshold tests are an important feature of the general value shifting regime. They ensure the rules are properly targeted at entities (affected owners) that can shape the transactions that create the value shift, or that are related to such entities.

If a value shift affects an asset or interest held by an entity that is not within this framework, any increase or decrease in its value is treated as a windfall for which there are no consequences under the regime.

Control tests:

  • are relevant for the entity interest direct value shifting rules and the indirect value shifting rules
  • are not relevant to the created rights direct value shifting rules.

See also