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.