63. Asset dealings between entities and members

Subject to section 46, where an asset is realised by way of transfer of ownership of the asset by an entity to one of its members or vice versa –

the transferor shall be treated as deriving an amount in respect of the realisation equal to the market value of the asset immediately before the realisation;

the transferee shall be treated as incurring expenditure of the amount referred to in paragraph (a) in the acquisition.