Income Tax Assessment Act 1997

CHAPTER 3 - SPECIALIST LIABILITY RULES  

PART 3-90 - CONSOLIDATED GROUPS  

Division 717 - International tax rules  

Subdivision 717-D - Transfer of certain surpluses under CFC provisions and former FIF and FLP provisions: entry rules  

Object

SECTION 717-205  

717-205   Object of this Subdivision  


The main object of this Subdivision is to avoid double taxation by transferring from a company (the joining company ) that becomes a * subsidiary member of a * consolidated group at a time (the joining time ) to the * head company of the group the benefit of each of these:


(a) the attribution surplus (if any) for an attribution account entity (within the meaning of Part X of the Income Tax Assessment Act 1936 ) in relation to the joining company just before the joining time;


(b) the post FIF abolition surplus (if any) (within the meaning of the Income Tax Assessment Act 1936 ) for a FIF attribution account entity (within the meaning of former Part XI of that Act) in relation to the joining company just before the joining time.


(c) (Repealed by No 114 of 2010)


(d) (Repealed by No 143 of 2007 )


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