Document ID: chunk:federal_register_of_legislation:C2025C00029:section:2:p13
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 2 (pt 13/66)
Character Range: 6357920–6360624

former Part XI of the Income Tax Assessment Act 1936.
FIF attribution account percentage has the same meaning as in former Part XI of the Income Tax Assessment Act 1936.
post FIF abolition credit has the same meaning as in the Income Tax Assessment Act 1936.
post FIF abolition debit has the same meaning as in the Income Tax Assessment Act 1936.
post FIF abolition surplus has the same meaning as in the Income Tax Assessment Act 1936.

717‑227  Deferred attribution credits
 (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) assuming the joining company had not done so, an attribution credit would have arisen under subsection 371(8) of that Act at a later time for an attribution account entity in relation to the joining company for the purposes of that Part.

Credit in relation to the head company
 (2) The attribution credit arises instead at the later time for the attribution account entity in relation to the *head company of the group.

Subdivision 717‑E—Transfer of certain surpluses under CFC provisions and former FIF and FLP provisions: exit rules

Guide to Subdivision 717‑E

717‑235  What this Subdivision is about
      Each attribution surplus and post FIF abolition surplus relating to a company that ceases to be a subsidiary member of a consolidated group is transferred to that company from the head company of the group.

Table of sections

Object
717‑240 Object of this Subdivision

Transfers
717‑245 Attribution surpluses
717‑255 FIF surpluses
717‑262 Deferred attribution credits

Object

717‑240  Object of this Subdivision
  The main object of this Subdivision is to avoid double taxation by transferring from the *head company of a *consolidated group to a company (the leaving company) that ceases to be a *subsidiary member of the group at a time (the leaving time) the benefit of each of these surpluses (to the extent that each surplus can be attributed to the leaving company):
 (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 head company just before the leaving time;
 (b) the post FIF abolition surplus (if any) (within the meaning of the Income Tax Assessment Act 1936) for a FIF attribution account entity (within the meaning of former Part XI of that Act) in relation to the head company just before the leaving time.

Transfers

717‑245  Attribution surpluses
 (1) This section operates for the purposes of Part X of the Income Tax Assessment Act 1936 if:
 (a) a company (the