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The Taxpayers' Guide 2013 - 2014, 25th Edition by Taxpayers Australia

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11.515   Value shifting

The General Value Shifting Regime (GVSR) (contained in Division 725) applies from 1 July 2002. Generally, the GVSR will affect equity and loan interests in companies and trusts where the owners of the interests satisfy a controller/associate test and the entities are not consolidated under the consolidations regime. A value shift occurs when something is done that results in the market value of one thing increasing (or being issued at a discount to market value), and the market value of another thing decreasing. The GVSR consists of three main areas.

Direct value shifting involving equity and loan interests in a single company or trust (Div 725)

Direct Value Shifting (DVS) rules apply where under a scheme value is shifted ...

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