The General Value Shifting regime is a tax ambush for all taxpayers. The rules are complicated and broad in their application. The provisions are designed to apply to traditional value shifts (eg issuing shares at a discount) and non-traditional value shifts (eg domestic transfer pricing). The rules can apply to companies and trusts.
This presentation focusses on the application of the rules in the context of:
- direct value shifting
- indirect value shifting
- consequences of triggering the provisions
- exemptions.