INCOME TAX ASSESSMENT ACT 1997

CHAPTER 3 - SPECIALIST LIABILITY RULES  

PART 3-90 - CONSOLIDATED GROUPS  

Division 717 - International tax rules  

Subdivision 717-D - Transfer of certain surpluses under CFC provisions and former FIF and FLP provisions: entry rules  

Transfers

SECTION 717-220   FIF surpluses  

717-220(1)  
This section operates for the purposes of sections 23AK and 23B of the Income Tax Assessment Act 1936 if:


(a) a company (the joining company ) becomes a * subsidiary member of a * consolidated group at a time (the joining time ); and


(b) just before the joining time there was a post FIF abolition surplus for a FIF attribution account entity in relation to the joining company for the purposes of those sections; and


(c) just before the joining time, the joining company ' s FIF attribution account percentage in relation to the FIF attribution account entity for the purposes of those sections was more than nil. Credit in relation to the head company

717-220(2)  
A post FIF abolition credit arises at the joining time for the FIF attribution account entity in relation to the * head company of the group. The credit is equal to the post FIF abolition surplus. Debit in relation to the joining company

717-220(3)  
A post FIF abolition debit arises at the joining time for the FIF attribution account entity in relation to the joining company. The debit is equal to the post FIF abolition surplus. Definitions

717-220(4)  
In this section:

FIF attribution account entity
has the same meaning as in former Part XI of the Income Tax Assessment Act 1936 .

FIF attribution account percentage
has the same meaning as in former Part XI of the Income Tax Assessment Act 1936 .

post FIF abolition credit
has the same meaning as in the Income Tax Assessment Act 1936 .

post FIF abolition debit
has the same meaning as in the Income Tax Assessment Act 1936 .

post FIF abolition surplus
has the same meaning as in the Income Tax Assessment Act 1936 .


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