Private ruling: Subsidiary members leaving a tax consolidated group
Published: February 2015

Ruling: In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided. | The taxpayer is the head company of a tax consolidated group. The taxpayer sought a ruling on the tax consequences of subsidiary members leaving the tax consolidated group. | The Commissioner ruled: | • on the application of the single entity rule in section 701-1 of the Income Tax Assessment Act 1997 (ITAA 1997); | • on the exit ACA calculation in accordance with section 711-20 of the ITAA 1997; | • on CGT events in accordance with Division 104 of the ITAA 1997; | • that Part IVA of the ITAA 1936 will not apply to the arrangement; and | • other matters.