Document ID: chunk:federal_register_of_legislation:C2014C00749:clause:6_2:p4
Version: federal_register_of_legislation:C2014C00749
Segment Type: clause
Provision Reference: sch 6 cl 2 (pt 4/5)
Character Range: 44146–46926

the joining year, do not include the amount of the joining entity's *excess foreign tax credits from a non‑membership period (if any) that ends at the same time the joining year ends.
[The next Subdivision is Subdivision 717‑D.]

Subdivision 717‑D—Attributable income: entry rules

Guide to Subdivision 717‑D

717‑200  What this Subdivision is about
      Each attribution surplus, attributed tax account surplus, FIF attribution surplus and FIF attributed tax account surplus relating to a company that becomes a subsidiary member of a consolidated group is transferred to the head company of the group.

Table of sections

Object
717‑205 Object of this Subdivision

Transfers
717‑210 Attribution surpluses
717‑215 Attributed tax account surpluses
717‑220 FIF attribution surpluses
717‑225 FIF attributed tax account surpluses
717‑230 Calculating FIF income where a company joins the group
[This is the end of the Guide.]

Object

717‑205  Object of this Subdivision
  The main object of this Subdivision is to avoid double taxation by transferring from a company (the joining company) that becomes a *subsidiary member of a *consolidated group at a time (the joining time) to the *head company of the group the benefit of each of these:
 (a) the attribution surplus (if any) for an attribution account entity (within the meaning of Part X of the Income Tax Assessment Act 1936) in relation to the joining company just before the joining time;
 (b) the attributed tax account surplus (if any) for an attribution account entity (within the meaning of Part X of the Income Tax Assessment Act 1936) in relation to the joining company just before the joining time;
 (c) the FIF attribution surplus (if any) for a FIF attribution account entity (within the meaning of Part XI of the Income Tax Assessment Act 1936) in relation to the joining company just before the joining time;
 (d) the FIF attributed tax account surplus (if any) for a *FIF (within the meaning of Part XI of the Income Tax Assessment Act 1936) in relation to the joining company just before the joining time.

Transfers

717‑210  Attribution surpluses
 (1) This section operates for the purposes of Part X of the Income Tax Assessment Act 1936 if:
 (a) a company (the joining company) becomes a *subsidiary member of a *consolidated group at a time (the joining time); and
 (b) just before the joining time there was an attribution surplus for an attribution account entity in relation to the joining company for the purposes of that Part; and
 (c) just before the joining time the joining company's attribution account percentage in relation to the attribution account entity for the purposes of that Part was more than nil.

Credit in relation to the head company
 (2) An attribution credit arises at the joining