(1) The main object of this Division is:
(a) to prevent inappropriate losses from arising on the realisation of * equity or loan interests from which value has been shifted to other equity or loan interests in the same entity; and
(b) to prevent inappropriate gains from arising on the realisation of equity or loan interests in the same entity to which the value has been shifted;
so far as those interests are owned by entities involved in the value shift.
(2) This is done by:
(a) adjusting the value of those interests for income tax purposes to take account of changes in * market value that are attributable to the value shift; and
(b) treating the value shift as a partial realisation to the extent that value is shifted:
(i) between interests held by different owners; or
(ii) in the case of interests in their character as CGT assets--from post-CGT assets to pre-CGT assets; or
(iii) between interests of different characters.