Income Tax Assessment Act 1997



Division 725 - Direct value shifting affecting interests in companies and trusts  

Guide to Division 725  

SECTION 725-1   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.


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