Document ID: chunk:federal_register_of_legislation:C2014C00749:clause:15_2:p1
Version: federal_register_of_legislation:C2014C00749
Segment Type: clause
Provision Reference: sch 15 cl 2 (pt 1/4)
Character Range: 378537–381196

2                                                              The ownership period is more than 4 years   $25,000,000

 (4) If the owner of the interest is an *affected owner because of item 1, 2, 3 or 4 in the table in subsection 727‑530(1) (about who is an affected owner), the time for the purposes of subparagraph (3)(a)(i) of this section is the latest of:
 (a) the start of the income year in which the *realisation event happens; and
 (b) the most recent time (if any), before or at the time of the *realisation event, when at least one of the group entities has the same *ultimate controller as the losing entity or the gaining entity; and
 (c) the start of the most recent period (if any):
 (i) that ended before or at the time of the realisation event; and
 (ii) within which at least one of the group entities has with the losing entity or with the gaining entity a *common‑ownership nexus.

727‑720  Abnormal service arrangement reduces value of losing entity that is not a group service provider by at least $500,000
 (1) It must be the case that at no time during the period when the owner owned the interest did the sole or dominant activity of the *losing entity consist of providing services as mentioned in subsection 727‑715(1).
 (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;
 (b) each *predominantly‑services indirect value shift that meets either of these conditions:
 (i) its amount was less than $500,000 and it happened within 4 years before the realisation event, or at the same time as the realisation event;
 (ii) its amount was $500,000 or more and it happened at any time before the realisation event, or at the same time as the realisation event;
  and that meets all of these conditions:
 (iii) the same entity is the losing entity for it as for the 95% services indirect value shift;
 (iv) it happened under a different *scheme from the 95% services indirect value shift; and
 (v) having regard to all relevant circumstances, it is reasonable to conclude that the sole or main reason why it happened under a different scheme was to prevent the conditions in section 727‑705, 727‑710, 727‑715 or this section from being met.
 (3) It must also be reasonable to conclude that the total market value is less than it would have been by at least:
 (a) $500,000, if the total of the *adjustable values, immediately before the *realisation event,