Income Tax Assessment Act 1997

CHAPTER 3 - SPECIALIST LIABILITY RULES  

PART 3-95 - VALUE SHIFTING  

Division 725 - Direct value shifting affecting interests in companies and trusts  

Subdivision 725-B - What is a direct value shift?  

SECTION 725-155   Meaning of down interests, decrease time, up interests and increase time  

725-155(1)    

An ^* equity or loan interest in the target entity is a down interest if a decrease in its *market value is reasonably attributable to the one or more things referred to in paragraph 725-145(1)(b) , and occurs at or after the time referred to in that paragraph. The time when the decrease happens is called the decrease time for that interest.

725-155(2)    

An ^* equity or loan interest in the target entity is an up interest if subsection 725-145(2) or (3) is satisfied for the interest. The time when the interest is issued at a ^* discount, or the increase in *market value happens, is called the increase time for that interest.