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

Last updated 14 May 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 the choice becomes irrevocable and the consolidated group 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 entry points of investment into Australia through Australian resident companies, special multiple entry consolidated (MEC) group rules will apply to the wholly owned resident companies and their wholly owned resident subsidiary entities.

The following losses and tax attributes can generally be brought into a consolidated group (or MEC group) when the group forms or a subsidiary member joins the group which is used by the group's head company:

  • Losses (including foreign losses)
  • Franking credits
  • Foreign dividend account balances
  • 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 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 our website.

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