Document ID: chunk:federal_register_of_legislation:C2014C00749:clause:6_5:p2
Version: federal_register_of_legislation:C2014C00749
Segment Type: clause
Provision Reference: sch 6 cl 5 (pt 2/3)
Character Range: 53878–56605

time; and
(c) mean that foreign investment fund income that accrued to the joining company from the FIF will be included in the joining company's assessable income and will give rise to a FIF attribution credit, and may also give rise to a FIF attribution debit, in relation to the joining company; and
(d) mean that the FIF attribution surplus and the FIF attributed tax account surplus for the FIF attribution account entity in relation to the joining company at the surplus time will take account of credits and debits arising at the credit/debit time and earlier.

Subdivision 717‑E—Attributable income: exit rules

Guide to Subdivision 717‑E

717‑235  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 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

Transfer of Part X surpluses
717‑245 Attribution surpluses
717‑250 Attributed tax account surpluses

Transfer of Part XI surpluses
717‑255 FIF attribution surpluses
717‑260 FIF attributed tax account surpluses
717‑265 Calculating FIF income where a company leaves the group
[This is the end of the Guide.]

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 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 head company just before the leaving 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 head company just before the leaving 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 head company just before the leaving time.

Transfer of Part X surpluses

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