(1) The purpose of this section is to prevent double counting of the * market value of the assets of a corporate group that:
(a) are not * taxable Australian real property; and
(b) are created under * arrangements under which corresponding liabilities are created in other members of the group.
(2) For the purposes of subsections 855-30(2) and (4), subsection (4) of this section applies to an asset that is not * taxable Australian real property if:
(a) the parties to an * arrangement included the 2 entities referred to in subsection (3); and
(b) an effect of the arrangement was to create, before the * CGT event happened:
(i) the asset as an asset of one of those 2 parties; and
(ii) a corresponding liability of the other (the other party ).
(3) The 2 entities are either:
(a) the first entity and the other entity (see subsection 855-30(3)), if table item 2 in subsection 855-30(4) applies to those entities; or
(i) that first entity or that other entity; and
(ii) an entity that is a first entity or other entity for the purposes of a related application of subsection 855-30(3) and table item 2 in subsection 855-30(4).
(a) if the other party is the test entity (see subsection 855-30(2))--the asset's * market value; or
(b) otherwise--the percentage of the asset's market value equal to the percentage that is the test entity's * total participation interest in the other party.
Example: The test entity loans money to its wholly-owned subsidiary. The market value of the loan asset created as an asset of the test entity is disregarded for the purposes of subsection 855-30(2).