Commonwealth Consolidated Acts Commonwealth Consolidated ActsThe purpose of this Division is to reduce a loss that would otherwise be * realised for income tax purposes by a * realisation event happening to an asset (except a * depreciating asset), to the extent that:
(a) value has been shifted out of the asset by the owner creating in an associate a right over the asset; and
(b) the value shifted was not brought to tax when the right was created and has not since been brought to tax on a realisation of the right.