Document ID: chunk:federal_register_of_legislation:C2025C00029:section:2:p10
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 2 (pt 10/66)
Character Range: 6350520–6353229

before that date.
Note: The effect is that the owner's cost base or reduced cost base will be the same as that of the originating company or transferor, as is the case with post‑CGT assets.

716‑860  CGT event straddling joining or leaving time
 (1) This section applies if:
 (a) an entity (the joining entity) becomes a subsidiary member of a *consolidated group at a particular time (the joining time); and
 (b) disregarding the operation of subsection 701‑1(1) (the single entity rule), the joining entity held a *CGT asset at the joining time; and
 (c) taking into account the operation of subsection 701‑1(1) (the single entity rule), the *head company of the group held the CGT asset at the joining time; and
 (d) a *CGT event happened in relation to the asset at a time before the joining time (disregarding this section), but the circumstances that gave rise to the CGT event first existed at a time on or after the joining time.
 (2) This section also applies if:
 (a) an entity (the leaving entity) ceases to be a *subsidiary member of a *consolidated group at a particular time (the leaving time); and
 (b) taking into account the operation of subsection 701‑1(1) (the single entity rule), the *head company of the group held a *CGT asset at the leaving time; and
 (c) disregarding the operation of subsection 701‑1(1) (the single entity rule), the leaving entity held the CGT asset at the leaving time; and
 (d) a *CGT event happened in relation to the asset at a time before the leaving time (disregarding this section), but the circumstances that gave rise to the CGT event first existed at a time on or after the leaving time.
 (3) For the purposes of this Act, treat the *CGT event as happening at the time when the circumstances that gave rise to the CGT event first existed.

Division 717—International tax rules

Table of Subdivisions
717‑A Foreign income tax offsets
717‑D Transfer of certain surpluses under CFC provisions and former FIF and FLP provisions: entry rules
717‑E Transfer of certain surpluses under CFC provisions and former FIF and FLP provisions: exit rules
717‑O Offshore banking units

Subdivision 717‑A—Foreign income tax offsets

717‑1  What this Subdivision is about
      If an entity becomes a subsidiary member of a consolidated group, the head company receives any tax offsets under section 770‑10 that arise because the entity pays foreign income tax while it is a subsidiary member of the group.

Table of sections

Object
717‑5 Object of this Subdivision

Foreign income tax on amounts in head company's assessable income
717‑10 Head company taken to be liable for subsidiary member's foreign income tax

Object

717‑5  Object of this Subdivision
  The object