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-C - Exclusions  

Miscellaneous

SECTION 727-260   Shift down a wholly-owned chain of entities  

727-260(1)    
An * indirect value shift does not have consequences under this Division if the * gaining entity is a * wholly-owned subsidiary of the * losing entity throughout the * IVS period.

Exception: impact on market value of primary loan interest

727-260(2)    


However, subsection (1) does not apply if the * indirect value shift has produced a * disaggregated attributable decrease, in the *market value of an * affected interest in the * losing entity that is also a * primary loan interest in an entity covered by subsection (3), for the owner of the interest.

727-260(3)    
This subsection covers:


(a) the * losing entity; and


(b) an entity that owns * primary equity interests in an entity that this subsection covers because of one or more previous applications of it.


 

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