Document ID: chunk:federal_register_of_legislation:C2014C00749:clause:15_3:p9
Version: federal_register_of_legislation:C2014C00749
Segment Type: clause
Provision Reference: sch 15 cl 3 (pt 9/10)
Character Range: 374630–377349

services have been provided in the income year (of the *losing entity) in which the realisation event happens, or in the previous income year.
 (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; and
 (b) all other *predominantly‑services indirect value shifts that satisfy subsection (1) (or that would satisfy it if they were *95% services indirect value shifts).
 (3) It must also be reasonable to conclude that the total market value is less than it would have been by at least:
 (a) $100,000, 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 $2,000,000; or
 (b) 5% of the total of those *adjustable values, if that total is greater than $2,000,000 and less than or equal to $10,000,000; or
 (c) $500,000, if that total is greater than $10,000,000.
 (4) For the purposes of subsections (2) and (3), disregard an *indirect value shift referred to in paragraph (2)(a) or (b) if services are provided directly by the *losing entity to the *gaining entity under the *scheme before the income year (of the losing entity) before the one in which the *realisation event happened.

727‑715  Service arrangements reduce value of losing entity that is a group service provider by at least $500,000
 (1) At some time during the period (the ownership period) when the owner owned the interest, the sole or dominant activity of the *losing entity must consist of providing services directly to one or more entities (the group entities) each of which is covered by one or more of the following paragraphs:
 (a) the *gaining entity;
 (b) an *affected owner;
 (c) an entity that has at that time the same *ultimate controller as the losing entity or the gaining entity;
 (d) if the conditions in section 727‑110 (common‑ownership nexus test) are satisfied for the *indirect value shift—an entity that has with the losing entity or with the gaining entity a *common‑ownership nexus within that period.
 (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; and
 (b) each *predominantly‑services indirect value shift for which the same entity is the losing