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Legislation
ATO documents that consider ITAA 1997 s 165-13
21 documents
Income tax: consolidation: can the transfer of a tax loss under section 707-120 of the Income Tax Assessment Act 1997, to the extent that it could have been utilised by the transferor in the trial year under section 165-20 of that Act, constitute a COT transfer?
Income tax: consolidation: can a tax loss, transferred under section 707-120 of the Income Tax Assessment Act 1997 to the extent that it could have been utilised by the transferor in the trial year under section 165-20 of that Act, satisfy the condition described in paragraph 707-350(1)(c) of the Income Tax (Transitional Provisions) Act 1997?
Group company loss transfers: change in ownership of holding company - loss company fails to satisfy the same business test
Group company loss transfers: change in ownership of holding company - income company fails to satisfy the same business test
Company losses: test time for same business test when a company has more than one majority change of ownership
Deducting tax loss of earlier income year: disqualifying change of company ownership in loss year - when company can deduct part of a tax loss
Consolidation: loss transfer testing - pattern of distributions test - a non-fixed trust holds fixed entitlements to 50% or more of the income or capital of a company
Consolidation: transfer testing - continuity of ownership test -a non-fixed trust holds fixed entitlements to 50% or more of the income or capital of the head company
Continuity of ownership test: listed public company - same people must control the voting power or company must carry on same business
Continuity of ownership test: listed public company - arrangements affecting beneficial ownership of shares
Company Tax Losses: same business test-whether it applies only to business carried on by a company in Australia
Company losses: continuity of ownership test - time of change in ownership of shares
Tax losses: transferring a loss for consolidation purposes - choosing not to apply Subdivision 166-A of the Income Tax Assessment Act 1997 - no effect on the head company subsequently using Subdivision 166-A when trying to utilise the transferred loss
Income tax: consolidation: can the transfer of a tax loss under section 707-120 of the Income Tax Assessment Act 1997, to the extent that it could have been utilised by the transferor in the trial year under section 165-20 of that Act, constitute a COT transfer?
Income tax: consolidation: can a tax loss, transferred under section 707-120 of the Income Tax Assessment Act 1997 to the extent that it could have been utilised by the transferor in the trial year under section 165-20 of that Act, satisfy the condition described in paragraph 707-350(1)(c) of the Income Tax (Transitional Provisions) Act 1997?
Continuity of ownership and test time for same business test.
Company losses: continuity of ownership test - shareholding change by order of the Family Court
Continuity of ownership tests: listed public company can't establish owners at start of test period - no abnormal trading in shares during loss year - test time for the same business test
Continuity of ownership tests: listed public company can't establish owners at start of test period - abnormal trading in shares during loss year - test time for the same business test
Company tax losses: same business test - not practicable to show continuity of ownership test satisfied for any period