Ruling Compendium TD 2014/23EC







This edited version of the Compendium of Comments is not intended to be relied upon. It provides no protection from primary tax, penalties, interest or sanctions for non-compliance with the law. | This is a compendium of responses to the issues raised by external parties to Draft Taxation Determination TD 2014/D5 Income tax: consolidation: if the conditions in subitem 50(5) of Part 4 of Schedule 3 to the Tax Laws Amendment (2012 Measures No.2) Act 2012 are satisfied and the original 2002 law applies to an assessment, will a subsequent request by the head company to amend that assessment result in the pre rules applying, by virtue of subitem 50(6), to the entire assessment or only to the subsequent amendment request? | This compendium of comments has been edited to maintain the anonymity of entities that commented on the Draft Determination. | Tax Office Response/Action taken | The Draft Determinations are very technical and very difficult to follow and understand. | It is acknowledged that this is the case, however, the law is complex in nature and therefore we have not found it possible to simplify the explanation, or to avoid using technical language without affecting their accuracy. As an aid to understanding, some additional paragraphs have been added which explain the principles behind the interpretative approach which has been taken.