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-G - The realisation time method  

Operative provisions

SECTION 727-640  

727-640   Merging equity or loan interests  


If 2 or more * equity or loan interests (the original interests ) in the * losing entity or in the * gaining entity are merged into 1 or more * equity or loan interests (the new interests ) at or after the * IVS time:


(a) each of the new interests inherits whatever characteristics would have been relevant to applying this Subdivision to the original interests if the merging had not happened; and


(b) those characteristics include characteristics inherited by any of the original interests because of any other application or applications of this section or section 727-635 ; and


(c) if a characteristic of any of the original interests involves an amount or quantity, the amount or quantity for that characteristic as inherited by any of the new interests is a reasonable proportion of the amount or quantity for that characteristic of the original interest.


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