INCOME TAX ASSESSMENT ACT 1997 (ARCHIVE)

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 820 - Thin capitalisation rules  

Subdivision 820-F - Thin capitalisation rules for resident TC groups  

How to construct a resident TC group for an income year

SECTION 820-515 (ARCHIVE)  

820-515   Partnerships, trusts, and Australian permanent establishments of foreign banks, included in a resident TC group  
A *resident TC group for an income year also includes:

(a) each partnership:

(i) all interests in whose income and capital are beneficially owned at the end of the income year by one or more companies in the group; and

(ii) for which the income year ends on the same day as for the companies in the group; and

(b) each trust:

(i) all interests in whose income and capital are beneficially owned at the end of the income year by one or more entities, each of which is a company in the group or is covered by paragraph (a); and

(ii) for which the income year ends on the same day as for the companies in the group; and

(c) for each *foreign bank:

(i) that is in the *maximum TC group and chooses to include its *Australian permanent establishments in the resident TC group; and

(ii) for which the income year ends on the same day as for the companies in the resident TC group;

each Australian permanent establishment through which the foreign bank carries on its banking business in Australia.