| Disclaimer This edited version has been archived due to the length of time since original publication. It should not be regarded as indicative of the ATO's current views. The law may have changed since original publication, and views in the edited version may also be affected by subsequent precedents and new approaches to the application of the law. You cannot rely on this record in your tax affairs. It is not binding and provides you with no protection (including from any underpaid tax, penalty or interest). In addition, this record is not an authority for the purposes of establishing a reasonably arguable position for you to apply to your own circumstances. For more information on the status of edited versions of private advice and reasons we publish them, see PS LA 2008/4. |
Edited version of your written advice
Authorisation Number: 1051486302337
Date of advice: 5 March 2019
Subject: Consolidation – tax cost setting – entry/joining calculation and allocations
The Commissioner has determined, based on the facts in the present case, that the arrangement under which the entities became subsidiary members of the consolidated group after the 15 February 2018 commenced before the 15 February 2018, such that the amendments repealing subsection 705-70(1A) and inserting subsection 705-70(1B) of Income Tax Assessment Act 1997 as introduced by Treasury Laws Amendment (Income Tax Consolidation Integrity) Act 2018 will not apply.