21 Sep 066 2 final Consolidation Determinations - TDs 2006/56-57On 20 September 2006, the ATO issued the following 2 final Taxation Determinations on Consolidation issues:
- TD 2006/56 Income tax: consolidation: cost setting: is a joining entity's entitlement to claim a deduction for (or to otherwise deal with) a tax loss an asset for the purposes of s 705-35 of ITAA 1997 if:
(a) the tax loss is the subject of a loss transfer agreement entered into after the joining entity became a member of the consolidated group;
(b) the loss transfer takes effect prior to that time; and
(c) the joining entity is entitled to a subvention payment?
(Previously released in draft form as TD 2005/D50: see 2005 TAXVINE No 41 (9) (21 October 2005))
- TD 2006/57 Income tax: consolidation: what is an excluded asset under s 705-35(2) of ITAA 1997? (Previously released in draft form as TD 2005/D54: see 2005 TAXVINE No 49 (10) (16 December 2005))