Income Tax Assessment Act 1997

CHAPTER 3 - SPECIALIST LIABILITY RULES  

PART 3-95 - VALUE SHIFTING  

Division 727 - Indirect value shifting affecting interests in companies and trusts, and arising from non-arm ' s length dealings  

Subdivision 727-A - Scope of the indirect value shifting rules  

SECTION 727-105  

727-105   Ultimate controller test  

It must be the case that, at some time during the ^* IVS period:

(a) the ^* losing entity and the ^* gaining entity have the same ^* ultimate controller; or

(b) the ultimate controller of the losing entity is the same entity that was the ultimate controller of the gaining entity at a different time during that period; or

(c) the gaining entity is the ultimate controller of the losing entity; or

(d) the losing entity is the ultimate controller of the gaining entity.

For the concept of IVS period , see section 727-150 .

For the concept of ultimate controller , see section 727-350 .