Private ruling: Impairment loss and conduit foreign income
Published: September 2014

Ruling: The ruling concerned the following: | 1. Is the impairment loss booked in the accounts of a subsidiary member of the tax consolidated group an expense reasonably related to the dividend received by that entity from a non-resident company, pursuant to subsection 802-30(5) of the Income Tax Assessment Act 1997 (ITAA 1997), and therefore a reduction to the head company of the tax consolidated group's conduit foreign income? | Decision | The Commissioner ruled that: | 1. No. The impairment loss booked in the accounts of a subsidiary member of the tax consolidated group is not an expense reasonably related to the dividend received by that entity from a non-resident company, pursuant to subsection 802-30(5) of the ITAA 1997, and therefore does not reduce the head company of the tax consolidated group's conduit foreign income.