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28 Sep 06 2 draft Consolidation Taxation Determinations - TD 2006/D41-D42

On 27 September, the ATO released the following 2 draft Taxation Determinations dealing with Consolidation for public comment by 27 October 2006:

- TD 2006/D41 Income tax: consolidation: subsidiary in liquidation - for the purposes of s 711-45(1) of ITAA1997, is the amount of an unsatisfied liability owed to another member of the consolidated group ('intra-group liability') by a subsidiary member at the time it is deregistered equal to the market value of the corresponding asset of that other member?  The answer given is Yes.

- TD 2006/D42 Income tax: consolidation: can a head company make a capital gain under CGT event L5 (s 104-520 of ITAA 1997) when a subsidiary member of the group is deregistered after liquidation?  The answer given is Yes.

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