Capital gains taxation on business trust units: deferred for SPV shareholders until units are disposed, affecting unit holders' tax treatment. Any capital gain on transfer of SPV shares to a business trust in exchange for units is exempt at transfer, with taxation deferred until the shareholder disposes the units; the units inherit the cost of acquisition and holding period of the shares. Ordinary unit holders benefit from STT linked long term exemption, while shareholders who received units in exchange for SPV shares are taxable on subsequent gains, with indexation available and differing short term tax treatment.