DIVISION SUBDIVISION SECTION IGT COMMENTS
Part III - Liability to Taxation
Division 1 - General   21A Non-cash business benefits The 'arm's length value' is used to account for non-cash business benefits.
Division 2 - Income Subdivision A - Assessable income generally 26AJ Investment-related lottery winnings to be included in assessable income The 'arm's length value' is used to account for property or services, reduced by the recipient's contribution (if any).
26BB Assessability of gain on disposal or redemption of traditional securities The 'arm's length consideration' is used to substitute for any gain assessable.
26BC Securities lending arrangements The 'market value' is used to account for eligible and borrowed securities.
Subdivision D - Dividends 44 Dividends The 'market value' is used to account for demerger dividends.
45BA Effect of determinations under section 45B for demerger benefits The 'market value consideration' is used to account for demerger benefits.
45C Effect of determinations under sections 45A and 45B for capital benefits The 'market value consideration' is used to account for capital benefits.
47A Distribution benefits - CFCs The 'arm's length value' is used to account for shares or units in relation to redemption or buy-back.
Division 3 - Deductions Subdivision A - General 51AK Agreements for the provision of non-deductible non-cash business benefits The 'arm's length value' is used to account for the benefit.
63E Debt/equity swaps The 'market value' is used to account for the equity value of shares or units.
70B Deduction for loss on disposal or redemption of traditional securities The 'arm's length consideration' is used work out the amount of any loss.
73A Expenditure on scientific research The 'market value' is used to account for the purchase of a building.
Subdivision H - Period of deductibility of certain advance expenditure 82KZMGB CGT event in relation to interest in 82KZMG agreement The 'market value' is used to account for interest.
Division 3A - Convertible notes   82L Interpretation Defines the relevant valuation period, in relation to a share.
82T Value of shares Defines the value of a fully paid share as at the valuation date.
Division 6AAA - Special provisions relating to non-resident trust estates etc. Subdivision A - Preliminary 102AAB Interpretation The 'market value' is used to account for the net worth (assets of the trust estate, reduced by the liabilities) in relation to a trust estate.
102AAK Deemed transfers of property or services to trust estate The 'market value' is used to account for the part transferred by a particular partner.
Subdivision D - Accruals system of taxation of certain non-resident trust estates 102AAZD Assessable income of attributable taxpayer to include attributable income of trust estate to which taxpayer has transferred property or services The 'market value' is used to account for the transferred property or services.
Division 6A - Alienation of income   102B Certain income transferred for short periods to be included in assessable income of transferor The 'arm's length consideration' is used to determine the application of subsection 102B(1) in respect of transfers.
Division 7 -Private Companies   103A Private companies The 'market value' is used to account for the share capital of a company when exercising the Commissioners discretion.
Division 7A - Distributions to entities connected with a private company Subdivision B - Private company payments, loans and debt forgiveness are treated as dividends 109CA Payment includes provision of asset The 'arm's length consideration' is used to determine the amount of a use payment.
Subdivision E - Payments and loans through interposed entities   The 'arm's length consideration' is used to ascertain the amount of the payment from the private company to the target entity.
Division 9AA - Demutualisation of insurance companies and affiliates Subdivision C - Tax consequences of demutualisation 121AS CGT consequences of demutualisation Company valuation amounts required.
Division 10E - PDFs (pooled development funds) Subdivision A - Shares in PDFs 124ZR Effect of company ceasing to be a PDF The 'market value' is used to account for CGT purposes.
Division 11A - Dividends, Interest and Royalties paid to Non-Residents and to Certain Other Persons   128AC - Deemed interest in respect of hire-purchase and certain other agreements The 'market value' is used to account for the relevant agreement property (eligible value).
Division 11B - Equity investments in small-medium enterprises     The 'market value' is used to account for consideration on the disposal of shares.
Division 16E - Accruals assessability, etc., in respect of certain security payments   159GZ Stripped securities The 'market value' is used to account for the underlying security.
Division 16J - Effect of cancellation of subsidiary's shares in holding company   159GZZZF Effect on subsidiary of share cancellations to which this division applies The 'market value' and 'adjusted market value' are used to account for shares.
  159GZZZG Pre-cancellation disposals of eligible interests The 'adjusted market value' is used to account for eligible interests.
Division 16K - Effect of buy-backs of shares Subdivision A - Interpretation 159GZZZM Purchase price in respect of buy-back The 'market value' is used to account for property other than money received in respect of a share buy-back.
Subdivision C - Off-market purchases 159GZZZQ Consideration in respect of off-market purchase The 'market value' is used to determine deemed consideration.
Division 16L - Tax-exempt infrastructure borrowings   159GZZZZE Infrastructure borrowings to be non-assessable and non-deductible The 'market value' is used to account for deemed re-acquisition after exemption period.
Part X - Attribution of Income in Respect of Controlled Foreign Companies
Division 7 - Calculation of attributable income of CFC Subdivision C - Modifications relating to Australian capital gains tax   The 'market value' is used to account for property included as part of payment.
Schedule 2D - Tax Exempt Entities that Become Taxable
Division 57 - Tax exempt entities that become taxable Subdivision 57-E - Assets and liabilities 57-25 Deemed disposal and re-acquisition of assets The 'adjusted market value' is used to account for consideration.
The 'adjusted market value' is used to account for cost base and reduced cost base.
Other market value requirements.
57-30 Deemed cessation and re-assumption of liabilities The 'market value' is used to account for the corresponding right or other asset (adjusted market value).
Schedule 2H - Demutualisation of Mutual Entities other than Insurance Companies and Health Insurers
Division 326 - Demutualisation Subdivision 326-D - CGT consequences of disposal of demutualisation shares or an interest in such shares by a member of a mutual entity where the entity or a holding company of the entity becomes a listed public company   The 'adjusted market value' is used formulas.
Subdivision 326-E - CGT consequences of disposal of demutualisation shares or interests in such shares by a member of a mutual entity where the entity or a holding company of the entity becomes a company that is not a listed public company   'Adjusted market value' requirements.