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  

Transfers

SECTION 717-210   Attribution surpluses  

717-210(1)    
This section operates for the purposes of Part X of the Income Tax Assessment Act 1936 if:


(a) a company (the joining company ) becomes a * subsidiary member of a * consolidated group at a time (the joining time ); and


(b) just before the joining time there was an attribution surplus for an attribution account entity in relation to the joining company for the purposes of that Part; and


(c) just before the joining time the joining company's attribution account percentage in relation to the attribution account entity for the purposes of that Part was more than nil.

Credit in relation to the head company

717-210(2)    
An attribution credit arises at the joining time for the attribution account entity in relation to the * head company of the group. The credit is equal to the attribution surplus.

Debit in relation to the joining company

717-210(3)    
An attribution debit arises at the joining time for the attribution account entity in relation to the joining company. The debit is equal to the attribution surplus.


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