Document ID: chunk:federal_register_of_legislation:C2009C00311:clause:1_2:p5
Version: federal_register_of_legislation:C2009C00311
Segment Type: clause
Provision Reference: sch 1 cl 2 (pt 5/5)
Character Range: 15871–16606

of the equity or debt for the *ultimate holding company is that part of the cost base of the qualifying interest worked out under section 124‑784B as:
 (a) may be reasonably allocated to the equity or debt; and
 (b) is not more than the *market value of the equity or debt at the completion time.

No capital gain on debt repayment

 (3) Any *capital gain of the *ultimate holding company from the repayment of new debt owed by an acquiring entity under the *arrangement is disregarded to the extent that it relates to the difference between the part of the *cost base worked out under section 124‑784B and the *market value of the debt at the completion time.

Note: If the debt is assigned or exchanged, there may be a capital gain.