Income Tax Assessment Act 1997

CHAPTER 3 - SPECIALIST LIABILITY RULES  

PART 3-90 - CONSOLIDATED GROUPS  

Division 715 - Interactions between this Part and other areas of the income tax law  

Subdivision 715-G - How value shifting rules apply to a consolidated group  

SECTION 715-410   Extension of single entity rule and entry history rule  

715-410(1)  
Subsection 701-1(1) (Single entity rule) and section 701-5 (Entry history rule) also have effect for all the purposes of Part 3-95 (Value shifting).

Note:

One consequence of this for the operation of Division 727 (about indirect value shifting affecting interests in companies and trusts, and arising from non-arm ' s length dealings) is that economic benefits provided by or to a subsidiary member of a consolidated group are treated as provided by or to the head company of the group. As a result:

  • · the head company is the only group member that can be a losing entity or gaining entity for an indirect value shift; and
  • · economic benefits provided by one group member to another are treated as provided by the head company to itself, and so have no relevance to Division 727 .
  • Another consequence is that the head company is treated as owning all interests owned by group members in a losing entity or gaining entity that is not a group member.

    715-410(2)  
    This section is not intended to limit the effect that subsection 701-1(1) and section 701-5 have apart from this section.


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