INCOME TAX ASSESSMENT ACT 1936 (ARCHIVE)
In order for the operative provisions of this Division (sections 160ZZRP and 160ZZRQ ) to apply, the following requirements must be satisfied:
(a) first, a share value shift must take place under an arrangement involving a company and a taxpayer (see section 160ZZRM );
(b) secondly, the taxpayer must be a controller (see subsection 160ZZRN(1)) of the company at some time during the period beginning when the arrangement is entered into and ending when it has been implemented;
(c) thirdly, there must be a material decrease (see subsection 160ZZRO(1)) in the market value of a share involved in the share value shift.
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