Document ID: chunk:federal_register_of_legislation:C2025C00029:section:4:p80
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 4 (pt 80/95)
Character Range: 5754244–5756980

body just before the disposal.
Note: Trading stock and depreciating assets are not revenue assets. See section 977‑50.
 (2) The body is taken to have disposed of the *revenue asset to the company for an amount such that the body would not make a profit or a loss on the disposal.
 (3) For the purpose of calculating any profit or loss on a future disposal of, cessation of owning, or other realisation of, the *revenue asset, the company is taken to have paid the body that amount for the disposal of the revenue asset to the company.

Ceasing to own or other realising
 (4) Subsection (5) applies to a *CGT asset:
 (a) that the body ceases to own, or otherwise realises, because the body ceases to exist; and
 (b) that is a *revenue asset of the body just before the cessation or realisation.
Note: Trading stock and depreciating assets are not revenue assets. See section 977‑50.
 (5) The body is taken to have disposed of the *revenue asset for an amount such that the body would not make a profit or a loss on the disposal.

Part 3‑90—Consolidated groups

Division 700—Guide and objects

Table of sections

Guide
700‑1 What this Part is about
700‑5 Overview of this Part

Objects
700‑10 Objects of this Part

Guide

700‑1  What this Part is about

      This Part allows certain groups of entities to be treated as single entities for income tax purposes.
      Following a choice to consolidate, subsidiary members are treated as part of the head company of the group rather than as separate income tax identities. The head company inherits their income tax history when they become subsidiary members of the group. On ceasing to be subsidiary members, they take with them an income tax history that recognises that they are different from when they became subsidiary members.
      This is supported by rules that:

                (a) set the cost for income tax purposes of assets that subsidiary members bring into the group; and
                (b) determine the income tax history that is taken into account when entities become, or cease to be, subsidiary members of the group; and
                (c) deal with the transfer of tax attributes such as losses and franking credits to the head company when entities become subsidiary members of the group.

700‑5  Overview of this Part
 (1) The single entity rule determines how the income tax liability of a consolidated group will be ascertained. The basic principle is contained in the Core Rules in Division 701.
 (2) Essentially, a consolidated group consists of an Australian resident head company and all of its Australian resident wholly‑owned subsidiaries (which may be companies, trusts or partnerships). Special rules apply to foreign‑owned groups with no single