Currency date is as specified. Sections will no longer be updated.
C1 – Eligibility
Currency date is as specified. Sections will no longer be updated.
Section |
Title |
Currency date |
|---|---|---|
About this section |
2 December 2002 |
|
Eligibility tests and rules |
26 October 2005 |
|
Business structures and eligibility |
26 October 2005 |
C2 – Assets
Currency date is as specified. Sections will no longer be updated.
Section |
Title |
Currency date |
|---|---|---|
About this section |
6 May 2011 |
C2.1: Treatment of assets
Section |
Title |
Currency date |
|---|---|---|
Treatment of assets |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
Overview of cost setting process on formation and entry (including transitional rules) |
6 May 2011 |
|
Calculating the entry ACA (step A) |
6 May 2011 |
|
Allocating the entry ACA (steps B to E) |
6 May 2011 |
|
Modifications to entry cost setting rules |
6 May 2011 |
|
Dealing with errors in TCSAs and changes in liabilities when discharged |
6 May 2011 |
|
Cost setting on exit |
6 May 2011 |
|
Treatment of special classes of assets |
15 July 2011 |
|
C2-1-080 |
Treatment of assets relating to straddle contracts |
Withdrawn 6 May 2011 |
Linked assets and liabilities |
6 May 2011 |
|
CGT events arising out of the cost setting rules |
6 May 2011 |
C2-2: High-level worked examples
Section |
Title |
Currency date |
|---|---|---|
The cost setting process on entry |
6 May 2011 |
|
Consolidated group joins another consolidated group |
6 May 2011 |
|
Linked entities join a consolidated group |
28 May 2003 |
|
A trust joins a consolidated group |
28 February 2008 |
|
Partnership - all partners join consolidated group |
14 July 2004 |
|
Partnership - not all partners join consolidated group |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
The cost setting process on exit |
6 May 2011 |
C2-3: Worksheets
Section |
Title |
Currency date |
|---|---|---|
Entry ACA worksheet |
6 May 2011 |
|
Over-depreciation worksheet |
6 May 2011 |
C2-4: Worked examples (cost setting on entry)
Section |
Title |
Currency date |
|---|---|---|
Transitional entities and chosen transitional entities |
16 December 2005 |
Section |
Title |
Currency date |
|---|---|---|
Calculating the ACA for non-chosen subsidiary partly held by chosen transitional entity |
6 May 2011 |
|
Amount to be used as cost for membership interests (ACA step 1) |
15 November 2006 |
|
Reduction for intragroup liabilities on entry (in ACA step 2) |
28 February 2008 |
|
Adjustment for employee shares (in ACA step 2) |
2 December 2002 |
|
Determining the amount of a deferred tax liability to be used at ACA step 2, including use of administrative short cuts |
6 May 2011 |
|
Adjustment at ACA step 2 to allow for timing differences between accounting and tax recognition of liabilities |
6 May 2011 |
|
C2-4-246 |
CGT event L7 and reconstruction of the ACA |
Withdrawn 6 May 2011 |
Estimating undistributed, frankable profits accruing to group before joining time (ACA step 3) |
6 May 2011 |
|
Determining undistributed, taxed (frankable) profits accrued to group before joining time (ACA step 3) |
6 May 2011 |
|
Pre-joining time rollover from foreign-resident company or a company that becomes the head company (ACA step 3A) |
6 May 2011 |
|
Adjustment at formation for distributions of profits to head company (ACA step 4) |
26 October 2005 |
|
Adjustments for losses (ACA steps 5 and 6) |
30 June 2009 |
|
Adjustment for certain inherited deductions (ACA step 7) |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
Tax cost setting amount for retained cost base assets - entitlement to pre-paid services |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
Tax cost setting amount for goodwill |
26 June 2007 |
|
Reduction for revenue-like assets (step C) |
26 October 2005 |
|
Adjustment for ACA allocation at formation to membership interests in subsidiaries with owned profits (step C) |
26 October 2005 |
Section |
Title |
Currency date |
|---|---|---|
Reduction for privatised depreciating assets (at step D) |
11 March 2005 |
|
Reduction for over-depreciated assets (step D) |
6 May 2011 |
|
Reduction for over-depreciated assets (step D) - administrative short cuts |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
Limiting the tax cost setting amounts of revenue-like assets (step E) |
6 May 2011 |
Section |
Title |
Curency date |
|---|---|---|
Pre-CGT factor for assets of a joining entity |
15 July 2011 |
|
Pre-CGT status of membership interests in a joining entity - pre-CGT proportion rules |
6 May 2011 |
|
Pre-CGT factor for assets where subsidiary has membership interests in another member - formation before 10 February 2010 |
6 May 2011 |
|
Applying the continuing majority-owned entity test to multi-tiered structures |
26 October 2005 |
C2-5: Worked examples (cost setting on exit)
Section |
Title |
Currency date |
|---|---|---|
Increase for certain privatised depreciating assets (at exit ACA step 1) |
6 May 2011 |
|
Adjustment for certain inherited deductions (exit ACA step 2) |
6 May 2011 |
|
Adjustment for intragroup liabilities owed to a leaving entity on exit (in exit ACA step 3) |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
Pre-CGT membership interests in a leaving entity (with pre-CGT factor attached to assets) |
6 May 2011 |
|
Pre-CGT membership interests in a leaving entity - per-CGT proportion rules |
6 May 2011 |
|
Calculating pre-CGT membership interests in a multiple exit case (with pre-CGT factor attached to assets) |
6 May 2011 |
|
Consolidated and MEC groups - CGT rollover relief |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
Continuing majority-owned entity and internally generated assets |
2 December 2002 |
C2-6: Loss integrity measures and general value shifting regime
Section |
Title |
Currency date |
|---|---|---|
Effect of Subdivision 165-CC for steps one and two of the ACA calculation at formation and joining times |
28 May 2003 |
|
Effect of Subdivision 165-CC where an entity leaves a consolidated group |
28 May 2003 |
|
Effect of Subdivision 165-CD for consolidated groups |
6 May 2011 |
|
Effect of Subdivision 165-CC for MEC groups |
28 May 2003 |
|
Effect of Subdivision 165-CD for MEC groups |
28 May 2003 |
|
Subdivision 165-CD widely held company concession for an eligible tier-1 company that is a head company of a consolidated or MEC group |
6 May 2011 |
|
Application of the loss reduction method to consolidated and MEC groups |
6 May 2011 |
|
General value shifting regime (GVSR) |
28 May 2003 |
Section |
Title |
Currency date |
|---|---|---|
Formation time treatment of assets head company owns from a pre-consolidation changeover time |
28 May 2003 |
|
Pre-formation changeover times - application of Subdivision 165-CC at formation (transitional period) |
28 May 2003 |
|
Treatment of assets owned by head company at both formation time and pre-consolidation changeover time (no changeover time at formation) |
28 May 2003 |
|
All assets in head company's loss denial pool become assets of leaving entity |
28 May 2003 |
C3 – Losses
Currency date is as specified. Sections will no longer be updated.
Section |
Title |
Currency date |
|---|---|---|
About this section |
15 April 2010 |
C3.1: Treatment of losses
Section |
Title |
Currency date |
|---|---|---|
Treatment of losses |
15 April 2010 |
C3-2: High-level worked example
Section |
Title |
Currency date |
|---|---|---|
Consolidation loss provisions |
2 December 2002 |
C3-3: Worked examples (loss transfer)
Section |
Title |
Currency date |
|---|---|---|
Utilising loss in non-membership period - non-membership period is taken to include joining time |
28 May 2003 |
|
Establishing unutilised loss at transfer time - single joining time and prior year loss case |
2 December 2002 |
|
Establishing unutilised loss at transfer time - multiple joining times and prior year and current year loss case |
28 May 2003 |
Section |
Title |
Currency date |
|---|---|---|
Transfer testing where no ownership or control failure - single joining time and joining year loss case |
28 May 2003 |
|
Transfer testing where ownership or control failed - single joining time and pre-1 July 1999 year loss case |
5 April 2004 |
|
Transfer testing with modified same business test - where ownership or control failed before trial year but after loss year |
5 April 2004 |
|
Transfer testing with modified same business test - where ownership or control failure in trial year but after loss year |
12 May 2004 |
|
Transfer testing with modified same business test - where head company transfers losses to itself |
12 May 2004 |
|
Transfer testing with modified same business test - acquisition of another consolidated group |
27 January 2005 |
|
Additional test for second or subsequent transfer of a loss previously transferred because the SBT was passed |
5 April 2004 |
|
Transfer testing where Subdivision 165-CC applies to a net capital loss that is unutilised at the joining time |
28 May 2003 |
|
Transfer testing where control or ownership failure and a change in business within the non-membership period |
3 November 2004 |
C3-4: Worked examples (loss utilisation)
Section |
Title |
Currency date |
|---|---|---|
Modified market value of a single joining entity |
2 December 2002 |
|
Calculating an available fraction - losses transferred for the first time where there has been a pre-joining injection of capital |
26 October 2005 |
Section |
Title |
Currency date |
|---|---|---|
Adding to modified market value to reflect loss transferability |
2 December 2002 |
|
Including value donor's losses in real loss-maker's bundle |
2 December 2002 |
|
Adding to modified market value to reflect loss transferability - loss made for an income year ending just before the initial transfer time |
28 May 2003 |
|
Adding to modified market value to reflect loss transferability - bundle includes foreign loss |
10 December 2004 |
|
Modified market value is nil where company has negative net assets |
3 December 2003 |
|
Donating a value donor's loss where modified market value is added to the value donor (in the capacity of a real loss-maker) |
16 December 2005 |
|
Losses transferred from members that are in liquidation can be used as basis for value and loss donation |
12 September 2006 |
|
Group waiver rule - disregarding reductions to modified market value caused by intragroup injections of capital |
12 September 2006 |
|
Single waiver rule - disregarding a reduction to modified market value caused by an injection of capital from a value donor |
27 January 2005 |
Section |
Title |
Currency date |
|---|---|---|
Adjusting available fraction - previously transferred losses are transferred again |
2 December 2002 |
|
Adjusting available fraction - transferred losses and group losses are transferred at the same time |
2 December 2002 |
|
Adjusting available fraction - another loss entity joins the group |
2 December 2002 |
|
Adjusting the available fraction - post-consolidation events that increase market value of group |
6 April 2006 |
|
Adjusting available fraction - post-consolidation injection of capital into subsidiary member |
6 April 2006 |
|
Adjusting available fraction - post-consolidation injection of capital where head company issues shares in scrip for scrip merger |
6 April 2006 |
|
Adjusting available fraction - multiple adjustments under a scrip for scrip acquisition |
15 April 2010 |
|
Adjusting available fraction - sum of available fractions is more than one |
2 December 2002 |
Section |
Title |
Currency date |
|---|---|---|
Amount of transferred losses that can be utilised |
2 December 2002 |
|
Amount of transferred losses that can be utilised - franking offsets |
23 April 2004 |
|
Amount of transferred losses that can be utilised - application of paragraph 36-17(5)(a) |
10 December 2004 |
|
Amount of transferred losses that can be utilised - application of paragraph 36-17(5)(b) |
10 December 2004 |
|
Amount of transferred losses that can be utilised - exempt income |
2 December 2002 |
|
Amount of losses that can be utilised - transferred tax losses utilised before group tax losses |
10 December 2004 |
|
Determining if a transferred loss can be utilised - COT transfer case |
3 December 2003 |
|
Cessation of a consolidated group - application of the SBT to the former head company |
26 June 2007 |
Section |
Title |
Currency date |
|---|---|---|
Transferred loss utilisation using value donor concession with transferred foreign losses |
26 October 2005 |
|
Concessional method for utilising transferred losses |
2 December 2002 |
|
Concessional method for utilising transferred losses - consolidation part-way through income year |
26 October 2005 |
|
Utilisation of transferred losses using both concessional and available fraction methods |
2 December 2002 |
|
Amount of CGT event L1 capital loss that can be utilised |
2 December 2002 |
|
Transitional foreign loss makers |
26 October 2005 |
|
Amount of transferred losses that can be utilised - foreign loss component of a tax loss |
30 June 2009 |
|
Transfer and utilisation of a tax loss with a foreign loss component where the loss maker joins part-way through the head company's income year |
15 April 2010 |
Section |
Title |
Currency date |
|---|---|---|
Apportioning the use of transferred losses |
2 December 2002 |
|
Apportioning the use of the head company's own losses |
28 May 2003 |
|
Apportioning the use of transferred losses in formation year |
10 December 2004 |
Section |
Title |
Currency date |
|---|---|---|
Transfer of tax losses from head company of consolidated group to Australian branch of a foreign bank |
28 May 2003 |
C3-5: Transfer of tax losses under Subdivision 170-A - consolidation part-way through the head company's income year
Section |
Title |
Currency date |
|---|---|---|
Transfer of tax losses under Subdivision 170-A - consolidation part-way through the head company's income year |
2 October 2003 |
|
Transfer of subsidiary member tax losses under Subdivision 170-A - consolidation part-way through the head company's income year |
2 October 2003 |
|
Transfer of a group tax loss under Subdivision 170-A - consolidation part-way through the head company's income year |
2 October 2003 |
|
Late loss transfers under Subdivision 170-A - consolidation and the Commissioner's discretion |
27 January 2005 |
C3-6: Determining the reduction amount - subsection 707-325(3)
Section |
Title |
Currency date |
|---|---|---|
Determining the reduction amount - subsection 707-325(3) |
18 May 2005 |
|
C3-6-110 |
Determining the reduction amount - multiple events, determining the initial increase in market value |
18 May 2005 |
Determining the reduction amount - diminution in value up to the joining time |
18 May 2005 |
|
Determining the reduction amount - injection of capital that does not result in increased modified market value |
18 May 2005 |
|
Determining the reduction amount - compounding of value up to the joining time |
18 May 2005 |
|
Determining the reduction amount - injection of capital subsequently injected into a subsidiary |
18 May 2005 |
|
Determining the reduction amount - multiple events, market value reduced under some events |
18 May 2005 |
C4 – Market valuation
Currency date is as specified. Sections will no longer be updated.
Section |
Title |
Currency date |
|---|---|---|
Market valuation |
6 May 2011 |
|
C4-1-110 |
Advance market valuation agreement - proforma |
Withdrawn 6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
C4-2-110 |
Taxation Determination TD 2003/10 |
Withdrawn 6 May 2011 |
C4-2-120 |
Taxation Determination TD 2003/11 |
Withdrawn 6 May 2011 |
C5 – Franking credits
Currency date is as specified. Sections will no longer be updated.
Section |
Title |
Currency date |
|---|---|---|
About this section |
28 May 2003 |
|
Treatment of franking credits |
28 May 2003 |
Section |
Title |
Currency date |
|---|---|---|
Franking accounts in consolidated groups |
28 May 2003 |
C6 – International
Currency date is as specified. Sections will no longer be updated.
Section |
Title |
Currency date |
|---|---|---|
About this section |
10 July 2009 |
|
Treatment of foreign income tax offsets, attribution surpluses and conduit foreign income |
6 May 2011 |
|
Thin capitalisation and consolidated groups |
26 June 2007 |
|
Foreign bank branches and consolidated groups |
12 May 2004 |
Section |
Title |
Currency date |
|---|---|---|
Pooling of excess foreign tax credits |
3 November 2004 |
|
Foreign income tax offsets - transitional rules |
30 June 2009 |
|
Calculating the foreign income tax offset |
30 June 2009 |
|
Transfer of attribution surpluses |
6 My 2011 |
|
Transfer of foreign dividend account balance |
28 May 2003 |
|
Treatment of conduit foreign income |
30 June 2009 |
C7 – Making a choice in writing and notifying
Currency date is as specified. Sections will no longer be updated.
Section |
Title |
Currency date |
|---|---|---|
About this section |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
Choice in writing |
6 May 2011 |
|
Consolidated groups - Notices to be given to the Commissioner |
6 May 2011 |
|
Impact of liquidation and deregistration |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
C7-2-110 |
Notification of formation of an income tax consolidated group |
Withdrawn 6 May 2011 |
C7-2-120 |
Notification of members joining and/or leaving the group |
Withdrawn 6 May 2011 |
C7-2-130 |
Notification of head company no longer eligible: group ceases to exist |
Withdrawn 6 May 2011 |
C8 – PAYG instalments
Currency date is as specified. Sections will no longer be updated.
Section |
Title |
Currency date |
|---|---|---|
About this section |
28 May 2003 |
|
Treatment of PAYG instalments |
15 April 2010 |
|
Completing the Consolidated activity statement |
28 May 2003 |
Section |
Title |
Currency date |
|---|---|---|
Consolidated activity statement |
2 December 2002 |
C9 – Determine tax liabilities, manage obligations
Currency date is as specified. Sections will no longer be updated.
Section |
Title |
Currency date |
|---|---|---|
About this section |
6 May 2011 |
C9-1: General information
Section |
Title |
Currency date |
|---|---|---|
Single entity treatment |
16 December 2005 |
|
Application of the consolidation provisions to cooperative companies |
26 October 2005 |
|
Income recognition - method used by head company |
26 October 2005 |
|
Tax-related expenses - post-consolidation expenses relating to a subsidiary's tax affairs |
30 June 2009 |
|
Application of Part IVA to elections to consolidate |
26 October 2005 |
C9-2: Record keeping guidelines and checklist
Section |
Title |
Currency date |
|---|---|---|
Record keeping guidelines and checklist |
6 May 2011 |
C9-3: Draft 2003 income tax return and schedules
Section |
Title |
Currency date |
|---|---|---|
C9-3 |
Draft 2003 income tax return and schedules |
Withdrawn 6 May 2011 |
C9-4: Special circumstances
Section |
Title |
Currency date |
|---|---|---|
Substituted accounting period (SAP) |
28 May 2003 |
C9-5: Worked examples
Section |
Title |
Currency date |
|---|---|---|
Calculating taxable income, income tax and losses for non-membership periods |
28 May 2003 |
|
Partners and partnerships - applying the part-year provisions |
26 October 2005 |
|
Effect of entry history rule |
6 May 2011 |
|
Aligning income/deductions with services - arrangements between prospective fellow members |
30 June 2009 |
|
Single entity treatment - deductibility of interest |
26 October 2005 |
|
Single entity treatment - sale of intragroup asset to non-member |
16 December 2005 |
|
Capital benefit paid in substitution for dividends |
12 September 2006 |
|
Capital allowances - with accelerated depreciation |
26 October 2005 |
|
Capital allowances - without accelerated depreciation |
23 December 2003 |
|
Treatment of trading stock brought into the group |
26 October 2005 |
|
Prepayment transitional rules - group consolidates 1 July 2002 |
3 December 2003 |
|
C9-5-340 |
Withdrawn 12 September 2006 |
|
Consumables brought into a group (transitional option) |
6 May 2011 |
|
Deducting a bad debt - company that is owed debt becomes member of consolidated group |
3 August 2005 |
|
Deducting a bad debt - company that is owed debt experiences majority ownership change when it joins consolidated group |
3 August 2005 |
|
Deducting a bad debt - company that is owed debt joins consolidated group that later ceases to exist |
3 August 2005 |
|
Effect of exit history rule |
6 May 2011 |
C9-6: Life insurance companies
Section |
Title |
Currency date |
|---|---|---|
Treatment of life insurance companies |
6 May 2011 |
|
Modified membership rules for consolidated groups that include a life insurance company |
6 May 2011 |
|
Modified membership rules for a joining life insurance company's wholly-owned subsidiary held indirectly through one or more interposed entities |
6 May 2011 |
|
Modified cost setting rules for consolidated groups that include a life insurance company |
6 May 2011 |
|
C9-6-530 |
Application of the single entity rule to a consolidated group that includes a life insurance company |
Withdrawn 6 May 2011 |
Value of the net risk component of life insurance policies when a life insurance company joins or leaves a consolidated group |
6 May 2011 |
|
Franking surpluses held by life insurance subsidiaries |
6 May 2011 |
C9-7: Tax sharing agreements
Section |
Title |
Currency date |
|---|---|---|
Tax sharing agreements |
30 June 2009 |
|
Tax sharing agreement based on percentage of profit methodology |
30 June 2009 |
C10 – Multiple entry consolidated (MEC) groups
Currency date is as specified. Sections will no longer be updated.
Section |
Title |
Currency date |
|---|---|---|
About this section |
6 May 2011 |
C10.1: Multiple entry consolidated (MEC) groups
Section |
Title |
Currency date |
|---|---|---|
Multiple entry consolidated (MEC) groups |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
MEC groups - notices to be given to the Commissioner |
6 May 2011 |
|
Group conversions |
6 May 2011 |
C10-2: Worked examples
Section |
Title |
Currency date |
|---|---|---|
Choice on formation, special conversion events and acquisition of new eligible tier-1 companies |
6 May 2011 |
|
Original and new eligible tier-1 companies of a MEC group |
6 May 2011 |
|
Transitional provisions for foreign-held, Australian-resident subsidiaries to be members of a MEC group |
26 October 2005 |
|
Provisional head company |
6 May 2011 |
|
A consolidated group is created from a MEC group |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
Cost setting rules for assets of a MEC group - at joining and formation times |
6 May 2011 |
|
Tax cost setting of assets - expansion of a MEC group to include new eligible tier-1 companies |
12 September 2006 |
Section |
Title |
Currency date |
|---|---|---|
Adjusting available fraction - a new eligible tier-1 company joins a MEC group |
12 September 2006 |
|
Apportioning the use of losses - new eligible tier-1 company joins part-way through income year |
15 April 2010 |
|
MEC groups and losses - determining whether the focal company satisfies the continuity of ownership test |
6 May 2011 |
|
Identifying the test company to determine continuity of ownership of the focal company in a MEC group - COT transfer of losses |
28 May 2003 |
|
Identifying the test company to determine continuity of ownership of the focal company in a MEC group - SBT satisfied |
28 May 2003 |
|
Determining the start of a test company's loss year to assess the continuity of ownership of the focal company in a MEC group (COT transfer of a loss) |
6 May 2011 |
|
Determining the start of a test company's loss year to assess continuity of ownership of the focal company in a MEC group (special conversion event) |
6 May 2011 |
|
Freezing the ownership of the test company - COT transfer of a loss to the head company of a MEC group |
28 May 2003 |
|
Freezing the ownership structure of a MEC group - when a loss-making company becomes head company of the group |
6 May 2011 |
|
Continuity of a potential MEC group when the identity of the top company changes - assumptions about the test company failing the COT |
6 May 2011 |
|
Assumptions about the test company failing the COT - potential MEC group ceases to exist |
6 May 2011 |
|
Assumptions about the test company failing the COT - MEC group ceases to exist because there ceases to be a provisional head company |
6 May 2011 |
|
Acquisition of part of a MEC group - transfer of losses to newly formed consolidated group |
6 May 2011 |
Section |
Title |
Currency date |
|---|---|---|
Events that trigger pooling in a MEC group |
26 October 2005 |
|
Pooling of external membership interests |
26 October 2005 |
|
An eligible tier-1 company leaving a MEC group |
6 May 2011 |
C10-3: Forms
Section |
Title |
Currency date |
|---|---|---|
C10-3-110 |
Notification of formation of a MEC group |
Withdrawn 6 May 2011 |
C10-3-120 |
Notification of members joining and/or leaving a MEC group |
Withdrawn 6 May 2011 |
C10-3-130 |
Notification of conversion to a MEC group |
Withdrawn 6 May 2011 |
C10-3-140 |
Notification of continuation of a MEC group with a new provisional head company |
Withdrawn 6 May 2011 |
C10-3-150 |
Notification of provisional head company no longer eligible MEC group |
Withdrawn 6 May 2011 |
See also:
Guidance on consolidation for income tax purposes. Last updated on 15 July 2011. The manual will no longer be updated.