Income Tax Assessment Act 1997
An * indirect value shift (see Subdivision 727-B ) has consequences under this Division if, and only if:
(a) the * losing entity is at the time of the indirect value shift a company or trust (except one listed in section 727-125 (about superannuation entities)); and
(b) in relation to either or both of the following:
(i) the losing entity * providing one or more economic benefits to the gaining entity * in connection with the * scheme from which the indirect value shift results;
the 2 entities are not dealing with each other at * arm ' s length; and
(ii) the gaining entity providing one or more economic benefits to the losing entity in connection with the scheme;
(c) either or both of sections 727-105 and 727-110 are satisfied; and
(d) no exclusion in Subdivision 727-C applies.
The consequences for direct and indirect interests in the losing entity or in the gaining entity are set out in Subdivision 727-F . If those consequences are to be worked out using the realisation time method (under Subdivision 727-G ), there are further exclusions for certain 95% services indirect value shifts: see section 727-700 .
An indirect value shift does not have consequences for interests in the losing entity or gaining entity owned immediately before the IVS time by an entity that:
See subsection 727-470(2) .