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 .


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