New Business Tax System (Consolidation and Other Measures) Act 2003 (16 of 2003)
Schedule 5 Consolidation: imputation rules
Income Tax Assessment Act 1997
5 Before Subdivision 719-J
Insert:
Subdivision 719-H - Imputation issues
719-425 Guide to Subdivision 719-H
This Subdivision deals with some imputation issues in relation to MEC groups.
Table of sections
Operative provisions
719-430 Transfer of franking account balance on cessation event
719-435 Distributions by subsidiary members of MEC group taken to be distributions by head company
[This is the end of the Guide.]
Operative provisions
719-430 Transfer of franking account balance on cessation event
(1) This section operates if:
(a) a *cessation event happens to the *provisional head company of a *MEC group (the former head company ); and
(b) another company (the new head company ) is appointed as the provisional head company of the group under subsection 719-60(3).
(2) When the new head company is appointed:
(a) the *franking account of the former head company ceases to operate; and
(b) the new head company has a franking account; and
(c) any *franking surplus or *franking deficit in the franking account of the former head company just before the *cessation event happened becomes that of the new head company.
719-435 Distributions by subsidiary members of MEC group taken to be distributions by head company
(1) Part 3-6 operates as if a *frankable distribution made by an *eligible tier-1 company that:
(a) is a member of a *MEC group; and
(b) is not the *provisional head company of the group;
had been made by the provisional head company of the group to a *member of the provisional head company.
Note: Part 3-6 deals with imputation.
(2) Part 3-6 operates as if a *frankable distribution made by a *subsidiary member of a *MEC group (the foreign-held subsidiary ) that is not an *eligible tier-1 company were a frankable distribution made by the *head company of the group to a *member of the head company if:
(a) the foreign-held subsidiary meets the set of requirements in section 703-45, section 701C-10 of the Income Tax (Transitional Provisions) Act 1997 or section 701C-15 of that Act; and
(b) the frankable distribution is made to a foreign resident.