Document ID: chunk:federal_register_of_legislation:C2025C00029:section:3:p14
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 3 (pt 14/32)
Character Range: 7226743–7229413

debt deduction of the establishment entity, so it is not disallowed by this Division as applying to the establishment entity.
Note 2: This Division also does not disallow a debt deduction that the head company or single company incurs during the grouping period and that consists of a cost that is:
• paid or owed to the establishment entity; and
• is attributable to an Australian permanent establishment covered by the choice under section 820‑597 or 820‑599.
 The cost is not a debt deduction of the head company or single company for the purposes of this Division as applying because of this Subdivision. This is because subsection 820‑603(3) or (4) treats the Australian permanent establishment as being part of the head company or single company, so the cost is treated as being paid or owed by the head company or single company to itself.

820‑607  Effect on test periods under this Division
  If, apart from this section, this Division (except this Subdivision) would have a single application to the *head company or single company, or to the establishment entity, in relation to a period (the test period) that:
 (a) is all or part of an income year of that entity; and
 (b) overlaps the grouping period;
this Division (except this section) is to have separate applications to that entity as follows:
 (c) a single application in relation to the period of overlap; and
 (d) a single application in relation to the part (if any) of the test period that is before the period of overlap; and
 (e) a single application in relation to the part (if any) of the test period that is after the period of overlap.

820‑609  Effect on classification of head company or single company
 (1) The *head company or single company is an outward investing entity (ADI) for a period (the trial period) that is all or part of the grouping period if:
 (a) apart from this Subdivision, the head company or single company would be an *outward investing entity (ADI) for the trial period; or
 (b) apart from this Subdivision, the head company or single company:
 (i) would be an *outward investing financial entity (non‑ADI) for the trial period; and
 (ii) at least one of the *Australian permanent establishments is a *permanent establishment through which a *foreign bank carries on banking *business in Australia.
 (2) The *head company is also an outward investing entity (ADI) for the trial period if, apart from this Subdivision:
 (a) section 820‑585 would prevent the disallowance of a *debt deduction for the income year including the trial period; or
 (b) section 820‑587 would apply Subdivision 820‑D to the head company as if it were an *outward investing entity (ADI) for