Document ID: chunk:federal_register_of_legislation:C2025C00014:section:47a:p7
Version: federal_register_of_legislation:C2025C00014
Segment Type: section
Provision Reference: s 47A (pt 7/13)
Character Range: 314817–317404

benefit was provided by the first company—the time of the provision of the benefit; or
 (ii) in any other case—the time, or each of the times, of the arrangement transfers concerned;
 (c) if the eligible benefit is a distribution benefit in relation to the first company—the distribution payment in relation to the distribution time is:
 (i) if the benefit was provided by the first company—the amount of the payment; or
 (ii) in any other case—so much of the amount or market value of the arrangement transfer as is attributable to the provision of the eligible benefit.
 (12) An eligible benefit that is covered by subsection (11) and provided at a particular time is not a distribution benefit in relation to the first company if, at that time, there is no entity (other than the provider referred to in that subsection) who is:
 (a) either:
 (i) the holder of an eligible equity interest in the first company; or
 (ii) an associate of an entity who is the holder of an eligible equity interest in the first company; and
 (b) the holder of an eligible equity interest in the recipient referred to in that subsection.
 (13) If:
 (a) apart from this subsection, a particular eligible benefit that is covered by subsection (8) or (11) and provided at a particular time is not a distribution benefit in relation to the first company only because of subsection (9) or (12); and
 (b) at a later time, there is an entity (other than the provider referred to in subsection (8) or (11), as the case may be) who is:
 (i) either:
 (A) the holder of an eligible equity interest in the first company; or
 (B) an associate of an entity who is the holder of an eligible equity interest in the first company; and
 (ii) the holder of an eligible equity interest in the recipient referred to in whichever of subsections (8) and (11) is applicable; and
 (ba) if the eligible benefit consists of the acquisition of a share or unit—at that later time, the share or unit has not been redeemed or bought back by the recipient mentioned in subsection (8) for a consideration equal to or greater than the arm's length value of the share or unit;
the following provisions have effect:
 (c) this section has effect as if subsection (9) or (12), as the case requires, had never applied in relation to that eligible benefit;
 (d) section 170 does not prevent the amendment of an assessment at any time for the purposes of giving effect to this subsection.
 (14) If:
 (a) apart from this subsection, a particular eligible benefit (in this subsection called the first eligible benefit) that is covered by subsection