Income Tax Assessment Act 1997
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Hide history noteSECTION 727-710 Ongoing or recent service arrangement reduces value of losing entity by at least $100,000 727-710(1)
Either or both of these must be true:
(a) when the * realisation event mentioned in subsection 727-700(1) happens, some or all of the services mentioned in paragraph 727-700(2)(a) or (b) have not yet been provided; or
(b) some or all of those services have been provided in the income year (of the * losing entity) in which the realisation event happens, or in the previous income year.
727-710(2)
It must be reasonable to conclude that the total (the total market value ) of the * market values, immediately before the * realisation event, of * primary interests in the * losing entity then owned by * affected owners is less than it would have been if none of the following had happened:
(a) the * 95% services indirect value shift; and
(b) all other * predominantly-services indirect value shifts that satisfy subsection (1) (or that would satisfy it if they were * 95% services indirect value shifts).
727-710(3)
It must also be reasonable to conclude that the total * market value is less than it would have been by at least:
(a) $100,000, if the total of the * adjustable values, immediately before the * realisation event, of the * primary interests referred to in subsection (2) is less than or equal to $2,000,000; or
(b) 5% of the total of those * adjustable values, if that total is greater than $2,000,000 and less than or equal to $10,000,000; or
(c) $500,000, if that total is greater than $10,000,000.
727-710(4)
For the purposes of subsections (2) and (3), disregard an * indirect value shift referred to in paragraph (2)(a) or (b) if services are provided directly by the * losing entity to the * gaining entity under the * scheme before the income year (of the losing entity) before the one in which the * realisation event happened.
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