Document ID: chunk:federal_register_of_legislation:C2025C00029:section:11:p11
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 11 (pt 11/20)
Character Range: 6655354–6657999

and only if:
 (a) the benefit has been, is being, is to be, or might be, provided under the scheme; or
 (b) the providing of the benefit is reasonably attributable to:
 (i) something that has been, is being, is to be, or might be, done or omitted under the scheme (whether before, at the time of, or after, the providing of the benefit) by an entity that is either of those entities or a third entity; or
 (ii) 2 or more such things.
 (2) An entity referred to in paragraph (1)(b) need not be a party to the *scheme. A benefit can be provided by act or omission.

727‑165  Preventing double‑counting of economic benefits

Rights to have economic benefits provided
 (1) If an economic benefit that has been, is being, is to be, or might be, *provided as mentioned in subsection 727‑150(3) or 727‑855(1) consists of a right to have economic benefits provided, that subsection applies to the right but does not also apply to those economic benefits.
Example: Acme Ltd enters into an agreement with Paragon Pty Ltd under which Acme is to provide services to Paragon over a 5 year period in return for payments.
 Paragon's rights under the agreement are economic benefits that Acme provides to Paragon when the agreement is made. The services are economic benefits that Acme is to provide to Paragon.
 Because of this subsection, the market value of the rights is taken into account in working out whether there has been an indirect value shift, but the market value of the services is not.

Effect of an economic benefit on interests in the entity to which it is provided
 (2) If an economic benefit has been, is being, or is to be, *provided to an entity, then, for the purposes of subsection 727‑150(3) or 727‑855(1), disregard an economic benefit to the extent that:
 (a) it consists of an increase in the *market value of:
 (i) an *equity or loan interest in the entity; or
 (ii) an *indirect equity or loan interest in the entity; and
 (b) the increase is reasonably attributable to the first‑mentioned benefit.

Subdivision 727‑C—Exclusions

Guide to Subdivision 727‑C

727‑200  What this Subdivision is about
      Some indirect value shifts do not have consequences under this Division.
Note 1: If the consequences of an indirect value shift are to be worked out using the realisation time method (under Subdivision 727‑G), there are further exclusions for certain 95% services indirect value shifts: see section 727‑700.
Note 2: For cases where there may be both a direct value shift and an indirect value shift, see Subdivision 727‑L.

Table of sections

General
727‑215 Amount does not exceed $50,000
727‑220 Disposal of asset at cost, or