This Part allows certain groups of entities to be treated as single entities for income tax purposes.

Following a choice to consolidate, subsidiary members are treated as part of the head company of the group rather than as separate income tax identities. The head company inherits their income tax history when they become subsidiary members of the group. On ceasing to be subsidiary members, they take with them an income tax history that recognises that they are different from when they became subsidiary members.

This is supported by rules that:

  (a)   set the cost for income tax purposes of assets that subsidiary members bring into the group; and

  (b)   determine the income tax history that is taken into account when entities become, or cease to be, subsidiary members of the group; and

  (c)   deal with the transfer of tax attributes such as losses and franking credits to the head company when entities become subsidiary members of the group.