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Legislation
ATO documents that consider ITAA 1997 s 166
20 documents
Company tax loss: 'person' other than company with tax loss obtains tax benefit in connection with scheme
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: a 'widely held company' that replaces another 'widely held company' for part of the income year - whether a widely held company 'at all times' during the income year
Company tax losses: is a 'corporate change' under section 166-175 of the ITAA 1997 taken not to have happened because of the effect of section 703-75 of the ITAA 1997
Company Tax Losses: loss company is a 100% subsidiary of more than one listed public company during the test period - whether the former concessional tracing rules apply
Company Tax Losses: loss company during the test period was initially a 100% subsidiary of a listed public company, and then a listed public company itself - whether the former concessional tracing rules apply
Company Tax Losses: 'no detriment' exception to concessional tracing rules - can an eligible Division 166 company form a belief on reasonable grounds by applying the former concessional tracing rules
Losses: bearer shares in foreign listed companies - disclosure of beneficial owners
Company tax losses: whether company can disregard concessional tracing rules that apply in relation to more than one stake as part of forming the necessary belief for the purposes of the 'no detriment' rule
Company tax losses: can a company form the necessary belief, on reasonable grounds, for the purposes of the 'no detriment' rule by applying the concessional tracing rules
Tax Losses-Continuity of Ownership Test (COT) and application of 'saving rule'
Continuity of ownership and test time for same business test.
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
Company tax losses: same business test - latest time practicable to show continuity of ownership test satisfied
Company bad debts: company unable to show continuity of ownership test satisfied for any period
Company tax losses - same business test - start-up company unable to show that continuity of ownership test satisfied for any period
Continuity of Ownership Test: listed public company - requirement that exactly the same shares or interests must continue to be held