Document ID: chunk:federal_register_of_legislation:C2014C00749:clause:6_5:p1
Version: federal_register_of_legislation:C2014C00749
Segment Type: clause
Provision Reference: sch 6 cl 5 (pt 1/3)
Character Range: 51325–54107

5                                                                    FIF attributed tax account debit                                                                                           Attribution debit

Note: Section 717‑230 may affect the calculation of the FIF attributed tax account surplus for the FIF in relation to the joining company just before the joining time.

717‑230  Calculating FIF income where a company joins the group
 (1) This section modifies the operation of Part XI 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) for the purposes of that Part, the FIF attribution account percentage of the joining company in relation to a FIF attribution account entity that is a *FIF is more than nil at the time (the surplus time) just before the joining time.
 (2) That Part operates in relation to the joining company as if a notional accounting period of the *FIF in relation to the joining company ended at the time (the credit/debit time) just before the surplus time.
 (3) That Part operates in relation to the joining company as if subsection 485(3) of that Act provided that the operative provision applied to the joining company in relation to the *FIF in respect of the notional accounting period of that FIF that ended in the year of income that included the credit/debit time.
 (4) Paragraph 538(2)(d) of that Act operates in relation to the *head company of the *consolidated group in relation to the *FIF in respect of the notional accounting period of that FIF that included the joining time as if:
 (a) the head company had acquired the interest or interests mentioned in that paragraph during that period (so far as those interests are held by the head company because the joining company became a *subsidiary member of the group); and
 (b) the amount or value of the consideration paid or given by the head company in respect of the acquisition was equal to the amount worked out under paragraph 538(2)(a) of that Act in relation to the joining company in relation to the FIF in respect of the notional accounting period mentioned in subsection (2) of this section.
Note: The modifications made by this section:
(a) apply if a company joins a consolidated group during a notional accounting period of a FIF in which the company has an interest; and
(b) allow the appropriate calculation of amounts attributed under FIF rules to the head company and joining company before and after the joining 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