Control threshold tests

'Control threshold tests' are an important feature of the general value shifting regime as 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. Where 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. Control tests are not relevant to the created rights direct value shifting rules.

The control threshold tests are explained in detail in section 6 of the Guide to the general value shifting regime.

    Last modified: 03 Feb 2016QC 16827