Document ID: chunk:federal_register_of_legislation:C2025C00029:section:3:p2
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 3 (pt 2/16)
Character Range: 6735518–6738268

this Subdivision because of the *indirect value shift; and
 (ii) those dividends were successively paid or distributed at the payment time by each entity interposed between the gaining entity and that affected owner; and
 (b) the amount (if any) that the *affected owner of the interest would receive (directly, or indirectly through one or more interposed entities) in respect of the interest if:
 (i) the gaining entity were to pay the total reduction amount at the payment time as a distribution of capital; and
 (ii) that capital was successively paid or distributed at the payment time by each entity interposed between the gaining entity and that affected owner.
 (6A) The reduction of *adjustable value that is to be taken into account under subparagraph (6)(a)(i) for an *equity or loan interest in the *losing entity is:
 (a) if the interest is *trading stock immediately before the *IVS time—the one worked out on the basis of the interest's adjustable value under subsection 727‑835(2); or
 (b) otherwise—the greater or greatest of these:
 (i) the reduction of the interest's *cost base;
 (ii) the reduction of the interest's *reduced cost base;
 (iii) the reduction (if any) worked out on the basis of the interest's adjustable value under subsection 727‑840(2) (about revenue assets).

Uplift not to exceed reasonable amount
 (7) If the uplift worked out as provided in subsections (4), (5) and (6) is not reasonable in the circumstances, having regard to the objects of this Division, the interest's *adjustable value is instead uplifted by an amount that is reasonable in the circumstances, having regard to those objects.
Note: The main object of this Division is set out in section 727‑95.

727‑805  Has there been a disaggregated attributable increase?
 (1) This section sets out how to determine whether an *indirect value shift has produced, for the owner of an *equity or loan interest, a disaggregated attributable increase in the *market value of the interest and, if so, the amount of it.
 (2) Make a reasonable estimate of the *market value of the interest at the *IVS time, but disregarding:
 (a) all effects on the market value of the interest during the *IVS period, except effects that are reasonably attributable to the *indirect value shift; and
 (b) the effects (if any) of the indirect value shift on the market value of *equity or loan interests, or *indirect equity or loan interests, in the losing entity.
(This result is called the notional resulting market value.)
Note: Paragraph (2)(b) is necessary because the market value of the interest may also have been affected by the decrease in the market value of interests in the losing entity, because the entity in which the interest is held had direct or indirect