Document ID: chunk:federal_register_of_legislation:C2024C00267:section:3:p13
Version: federal_register_of_legislation:C2024C00267
Segment Type: section
Provision Reference: s 3 (pt 13/17)
Character Range: 595088–597960

membership interests were disregarded; and
 (b) only the following proportion of each of the step 2 to step 7 amounts in the table in section 705‑60 of the Income Tax Assessment Act 1997 was taken into account:

  where:
  market value of all membership interests in non‑chosen subsidiary means the market value, at the time the group comes into existence, of all membership interests in the non‑chosen subsidiary that are held by entities that become members of the group at that time.
  market value of head company's direct and indirect membership interests in non‑chosen subsidiary means the market value, at the time the group comes into existence, of all membership interests in the non‑chosen subsidiary that the head company holds directly or indirectly through interposed entities that become subsidiary members of the group at that time and are not included in any sub‑group in relation to the non‑chosen subsidiary.

Sub‑group's notional allocable cost amount
 (5) For each sub‑group that exists in relation to the non‑chosen subsidiary, there is a sub‑group's notional allocable cost amount. That amount is the amount that would be a consolidated group's allocable cost amount for the non‑chosen subsidiary if:
 (a) the consolidated group came into existence at the same time as the transitional group and consisted only of the non‑chosen subsidiary and the entities comprising the sub‑group; and
 (b) the chosen transitional entity in the sub‑group were the head company of the consolidated group; and
 (c) the only membership interests that any entity held at or before that time in any other entity that became a member of the consolidated group were the sub‑group membership interests (see subsection (6)) in relation to the sub‑group, and any such entity held those membership interests during the period when it actually held them; and
 (d) only the following proportion of each of the step 2 to step 7 amounts in the table in section 705‑60 of the Income Tax Assessment Act 1997 was taken into account:

  where:
  market value of all membership interests in non‑chosen subsidiary means the market value, at the time the group comes into existence, of all membership interests in the non‑chosen subsidiary that are held by entities that become members of the group at that time.
  market value of chosen transitional entity's direct and indirect membership interests in non‑chosen subsidiary means the market value, at the time the group comes into existence, of all membership interests in the non‑chosen subsidiary that the chosen transitional entity holds directly or indirectly through interposed entities that are included in the sub‑group.

Sub‑group and sub‑group membership interests
 (6) If a chosen transitional entity holds membership interests in a non‑chosen subsidiary, either directly or indirectly through one or more other entities,