Private ruling: Conversion of consolidated group to a MEC group
Date of advice: 15 June 2021
Published: August 2021
Ruling period: Income Tax year ended 30 June 20xx
Date scheme commenced: Income tax year beginning 1 July 20xx

Ruling: Q1: 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? | A1: Yes

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.



This ruling applies for the following period: