SPECIALIST LIABILITY RULES
Direct value shifting affecting interests in companies and trusts
Guide to Division 725
What this Division is about
If, under a scheme, value is shifted from equity or loan interests in a company or trust to other equity or loan interests in the same company or trust (including interests issued at a discount), this Division:
(a) adjusts the value of those interests for income tax purposes to take account of material changes in market value that are attributable to the value shift; and
(b) treats the value shift as a partial realisation to the extent that value is shifted between interests held by different owners, and in some other cases.
However, it does so only for interests that are owned by entities involved in the value shift.