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Chapter 10: Consolidation (consolidated income tax treatment for groups of entities)

Last updated 31 March 2020


For income tax purposes, consolidation is optional. However, if the head company of a wholly owned resident group decides to consolidate, all its wholly owned Australian resident group entities must become members of that consolidated group.

Once a group has consolidated, it is treated as a single entity for income tax purposes. If a foreign company, either directly or through its wholly owned foreign group, has multiple investment points into Australia through Australian resident companies, special multiple entry consolidated groups rules will apply to the wholly owned resident companies and their wholly owned resident subsidiary entities.

The head company of that consolidated group can generally bring into a consolidated group and use individual entity losses (including foreign losses), franking credits, excess foreign tax credits, attribution account surpluses and attribution tax account surpluses.

Note: This chapter provides a summary of the provisions on the application of income attributed from foreign investment funds (FIFs) and included in the assessable income of a head company of a consolidated group. Detailed information on the operation of consolidation is in the Consolidation reference manual, which provides information on the operation of consolidation, including its practical effects for business. The manual and legislation are available on the Tax Office website at

If you have tax technical queries, phone the Business Tax Reform Infoline on 13 24 78 or email us at