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Edited version of private advice
Authorisation Number: 1051848417253
Date of advice: 15 June 2021
Ruling
Subject: Conversion of consolidated group to a MEC group
Question
Will Company G be entitled to make choice under paragraph 719-40(1)(e) to convert to a MEC group (including itself as provisional head company (PHC)) and Company S as the other eligible-tier-1 company) pursuant to a 'special conversion event' under section 719-40 of the ITAA 1997?
Answer
Yes
This ruling applies for the following period:
Income Tax year ended 30 June 20xx
The scheme commences on:
Income tax year beginning 1 July 20xx
Relevant facts and circumstances
Company G is the head company of a tax consolidated group and an eligible tier-1 company of the top company T Coy.
Company S will become an eligible tier-1 company of the top company (T Coy) on T Coy acquiring all the shares in Company S (from Company A).
Company G will be entitled to make a choice under paragraph 719-40(1)(e) to convert to a MEC group (including itself as provisional head company and Company S as the other eligible tier-1 company) on Company S becoming an eligible tier-1 company of the top company T Coy.