Document ID: chunk:federal_register_of_legislation:C2025C00029:section:3:p9
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 3 (pt 9/10)
Character Range: 6718622–6721347

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 entity as for the 95% services indirect value shift, and that happened:
 (i)