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28 documents
Income tax: consolidation: cost setting: are the tax costs of the assets of a transitional foreign-held indirect subsidiary which is not a chosen transitional entity set when the entity becomes a member of a consolidated or MEC group?
Income tax: consolidation: imputation: will the benchmark rule in section 203-25 of the Income Tax Assessment Act 1997 apply in a franking period to the provisional head company of a MEC group if it is a 100% subsidiary of a foreign parent company that has more than one class of membership interest on issue?
Income tax: consolidation: imputation: which entity in a MEC group is responsible for meeting obligations imposed by Part 3-6 (the imputation provisions) of the Income Tax Assessment Act 1997 in relation to a frankable distribution made to members outside the group by an eligible tier-1 company in the group that is not the provisional head company?
Income tax: consolidation: can the head company of a multiple entry consolidated group claim a deduction under section 8-1 of the Income Tax Assessment Act 1997 for interest paid on funds borrowed after formation of the MEC group from outside the group by it or a subsidiary member to buy shares in an existing eligible tier-1 company of the group?
Income tax: consolidation: losses: when a company that joins an existing MEC group is an eligible tier-1 company, do prior group losses of the head company of that group become subject to the loss utilisation rules in Subdivision 707-C of the Income Tax Assessment Act 1997?
Income tax: consolidation: cost setting: is a joining entity's entitlement to claim a deduction for (or to otherwise deal with) a tax loss an asset for the purposes of section 705-35 of the Income Tax Assessment Act 1997 if: (a) the tax loss is the subject of a loss transfer agreement entered into after the joining entity became a member of the consolidated group; (b) the loss transfer takes effect prior to that time; and (c) the joining entity is entitled to a subvention payment?
Income tax: is the 'applicable functional currency' for the head company of a consolidated group determined by looking at the 'accounts' of all the members of the consolidated group, for the purposes of item 1 of subsection 960-60(1) of the Income Tax Assessment Act 1997 ?
Income tax: application of the same business test to consolidated and MEC groups - principally, the interaction between section 165-210 and section 701-1 of the Income Tax Assessment Act 1997