Document ID: chunk:federal_register_of_legislation:C2025C00029:section:2:p2
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 2 (pt 2/4)
Character Range: 6724876–6727765

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, of the *primary interests referred to in subsection (2) is less than or equal to $10,000,000; or
 (b) 5% of the total of those *adjustable values, if that total is greater than $10,000,000 and less than or equal to $100,000,000; or
 (c) $5,000,000, if that total is greater than $100,000,000.
 (4) The providing of the services mentioned in paragraph 727‑700(2)(a) or (b) by the losing entity must not be in the ordinary course of its business.

727‑725  Meaning of predominantly‑services indirect value shift
  An *indirect value shift is a predominantly‑services indirect value shift if, and only if, the *greater benefits consist entirely or predominantly of:
 (a) a right to have services that are covered by section 727‑240 provided directly by the *losing entity to the *gaining entity; or
 (b) services that are covered by section 727‑240 and have been, are being, or are to be, so provided;
or both.

Subdivision 727‑H—The adjustable value method

Guide to Subdivision 727‑H

727‑750  What this Subdivision is about

      Under the adjustable value method:
         • the adjustable values of affected interests in the losing entity are reduced; and
         • the adjustable values of affected interests in the gaining entity are uplifted, within limits worked out by references to the reductions in the adjustable values of affected interests in the losing entity.
      The consequences of that are:
         • the cost base and reduced cost base of the interests are reduced or uplifted (or both); and
         • if the interests are also trading stock or revenue assets, there are further consequences for them in their character as such.

Table of sections
727‑755 Consequences of indirect value shift

Reductions of adjustable value
727‑770 Reduction under the adjustable value method
727‑775 Has there been a disaggregated attributable decrease?
727‑780 Working out the reduction on a loss‑focussed basis

Uplifts of adjustable value
727‑800 Uplift under the attributable increase method
727‑805 Has there been a disaggregated attributable increase?
727‑810 Scaling‑down formula

Consequences of the method for various kinds of assets
727‑830 CGT assets
727‑835 Trading stock
727‑840 Revenue assets

727‑755  Consequences of indirect value shift
 (1) This