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INCOME TAX ASSESSMENT ACT 1997 - SECT 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 leaving company ) ceases to be a * subsidiary member of a * consolidated group at a time (the leaving time ); and

  (b)   just before the leaving time there was, for the purposes of that Part, an attribution surplus for an attribution account entity in relation to the * head company of the group; and

  (c)   at the leaving time the leaving company's attribution account percentage in relation to the attribution account entity for the purposes of that Part   is more than nil.

Credit in relation to leaving company

  (2)   An attribution credit arises at the leaving time for the attribution account entity in relation to the leaving company. The credit is the amount worked out under subsection   (4).

Debit in relation to head company

  (3)   An attribution debit arises at the leaving time for the attribution account entity in relation to the company that was the * head company of the group just before the leaving time. The debit is the amount worked out under subsection   (4).

Amount of credit and debit

  (4)   The amount of the credit and debit is worked out using the formula:

Start formula start fraction Leaving company's attribution account percentage in relation to the attribution account entity at the leaving time over *Head company's attribution account percentage in relation to the attribution account entity just before the leaving time end fraction times Attribution surplus for the attribution account entity in relation to the *head company just before the leaving time end formula


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