Income Tax Assessment Act 1997

CHAPTER 3 - SPECIALIST LIABILITY RULES  

PART 3-90 - CONSOLIDATED GROUPS  

Division 717 - International tax rules  

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

Object

SECTION 717-240  

717-240   Object of this Subdivision  


The main object of this Subdivision is to avoid double taxation by transferring from the * head company of a * consolidated group to a company (the leaving company ) that ceases to be a * subsidiary member of the group at a time (the leaving time ) the benefit of each of these surpluses (to the extent that each surplus can be attributed to the leaving company):


(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 head company just before the leaving 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 head company just before the leaving time.


(c) (Repealed by No 114 of 2010)


(d) (Repealed by No 143 of 2007 )


 

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