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Legislation
ATO documents that consider ITAA 1997 s 165-A
14 documents
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
Deducting Tax Loss: Saving Rule - More than one tax loss being deducted
Company losses: shares in loss company held by corporate trustee of non-fixed trust - whether shareholders of corporate trustee beneficially own the shares
Company Losses- applying a part year net capital 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
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
Research and Development: Carry forward R&D tax offsets at joining time for a consolidated group
Income tax: capital gains: if a company seeks to carry forward a net capital loss but fails the continuing ownership test, can it rely on the same business test as set out in section 80E?
Tax Losses-Continuity of Ownership Test (COT) and application of 'saving rule'
Deducting tax loss: saving rule - loss transfer