Income Tax Act 2007 section 809AZG

Interpretation

Section 809AZG defines what counts as a "transfer of assets" for the purposes of this chapter, giving the term a deliberately broad meaning that extends well beyond simple sales.

  • Granting or surrendering a lease of land, and disposing of an interest in an oil licence, are both treated as transfers of the underlying asset.
  • The term "transfer" covers sales, exchanges, gifts, assignments, and any other arrangement that is in substance equivalent to a transfer.
  • Where the transaction is an arrangement rather than a straightforward sale, exchange, gift or assignment, the transfer is treated as taking place when the arrangement is made.
  • Transfers involving partnerships where the transferor or transferee is a member, or trusts where the transferor is a beneficiary, fall within the scope of this chapter.

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