Document ID: chunk:federal_register_of_legislation:C2014C00749:clause:15_1:p14
Version: federal_register_of_legislation:C2014C00749
Segment Type: clause
Provision Reference: sch 15 cl 1 (pt 14/18)
Character Range: 250561–253187

value of the down interests; and
 (b) the issue at a *discount of the up interests covered by subsection 725‑145(2); and
 (c) the increases in market value of the up interests covered by subsection 725‑145(3).
 (3) This Division also proceeds on the basis that the *direct value shift is from each of the *down interests to each of the *up interests.

725‑165  If market value decrease or increase is only partly attributable to the scheme
  If it is reasonable to conclude that an increase or decrease in market value, or the issuing of an *equity or loan interest at a *discount, is only partly caused by the doing of the one or more things under the *scheme, this Division applies to the increase, decrease, or issue at a discount, to that extent only.

Subdivision 725‑C—Consequences of a direct value shift

Table of sections

General
725‑205 Consequences depend on character of down interests and up interests
725‑210 Consequences for down interests depend on pre‑shift gains and losses

Special cases
725‑220 Neutral direct value shifts
725‑225 Issue of bonus shares or units
725‑230 Off‑market buy‑backs

General

725‑205  Consequences depend on character of down interests and up interests
 (1) The consequences for you of the *direct value shift depend on the character of the *down interests and *up interests of which you are an *affected owner.
 (2) There are consequences for all your *down interests and *up interests in their character as *CGT assets. However, some of them may also be *trading stock or *revenue assets. There are additional consequences for those interests in their character as trading stock or revenue assets.
Note: For example, you may own a down interest that is a CGT asset and a revenue asset.
 Sections 725‑240 to 725‑255 set out the consequences for you of a shift in value from that interest in its character as a CGT asset. The cost base of the asset will be decreased, which will affect the calculation of a capital gain when a CGT event happens to the interest.
 Section 725‑320 sets out the consequences for you of a shift in value from that interest in its character as a revenue asset. The adjustment made under that section will affect the calculation of any profit on the sale of the interest.
 Any overlap between the capital gain and the profit realised on the sale of the interest is then dealt with under section 118‑20.
 In some instances, the direct value shift may result in a taxing event generating a gain for you in the income year in which the shift happens. That gain will be both a capital gain (because the down interest can be characterised as a CGT asset) and