This Division adjusts the cost bases of shares and loans in certain cases where assets are transferred between companies under common ownership and the transfer is likely to reduce the value of the share or loan.

• There are detailed rules for the circumstances in which adjustments are made and the amount of those adjustments.

• The rules that apply to most depreciable assets are different from the rules that apply to transfers of other assets.

• Taxpayers are able to group certain assets before applying this Division. In some cases, this will result in no adjustment being required and in some other cases it will result in a lesser reduction being required. Taxpayers may also choose to group certain assets for administrative convenience.