Document ID: chunk:federal_register_of_legislation:C2025C00029:section:4:p17
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 4 (pt 17/30)
Character Range: 7822533–7825211

975‑500 Wholly‑owned groups
975‑505 What is a 100% subsidiary?

975‑500  Wholly‑owned groups
  Two companies are members of the same wholly‑owned group if:
 (a) one of the companies is a *100% subsidiary of the other company; or
 (b) each of the companies is a *100% subsidiary of the same third company.

975‑505  What is a 100% subsidiary?
 (1) A company (the subsidiary company) is a 100% subsidiary of another company (the holding company) if all the *shares in the subsidiary company are beneficially owned by:
 (a) the holding company; or
 (b) one or more 100% subsidiaries of the holding company; or
 (c) the holding company and one or more 100% subsidiaries of the holding company.
 (2) However, the subsidiary company is not a 100% subsidiary of the holding company if a person is *in a position to affect rights, in relation to the subsidiary company, of:
 (a) the holding company; or
 (b) a 100% subsidiary of the holding company.
 (3) The subsidiary company is also not a 100% subsidiary of the holding company if at some future time a person will be *in a position to affect rights as described in subsection (2).
 (4) A company (other than the subsidiary company) is a 100% subsidiary of the holding company if, and only if:
 (a) it is a 100% subsidiary of the holding company; or
 (b) it is a 100% subsidiary of a 100% subsidiary of the holding company;
because of any other application or applications of this section.

Division 976—Imputation

Table of sections
976‑1 Franked part of a distribution
976‑5 Unfranked part of a distribution
976‑10 The part of a distribution that is franked with an exempting credit
976‑15 The part of a distribution that is franked with a venture capital credit

976‑1  Franked part of a distribution
  The franked part of a *distribution is an amount worked out using the formula:
where:
applicable gross‑up rate means the *corporate tax gross‑up rate of the entity making the distribution for the income year in which the distribution is made.

976‑5  Unfranked part of a distribution
  The unfranked part of a *distribution is the amount that is left after deducting the *franked part of the distribution from the total distribution.

976‑10  The part of a distribution that is franked with an exempting credit
  The part of a distribution that is franked with an exempting credit is worked out using the formula:
where:
applicable gross‑up rate means the *corporate tax gross‑up rate of the entity making the distribution for the income year in which the distribution is made.

976‑15  The part of a distribution that is franked with a venture capital credit
  The part of a distribution that is franked with a venture capital