Work out the joined group's allocable cost amount for the joining entity in this way:
Working out the joined group's allocable cost amount for the joining entity | ||
Step | What the step requires | Purpose of the step |
1 | Start with the step 1 amount worked out under section 705 - 65, which is about the cost of * membership interests in the joining entity held by * members of the joined group | To ensure that the allocable cost amount includes the cost of * acquiring the membership interests |
2 | Add to the result of step 1 the step 2 amount worked out under section 705 - 70, which is about the value of the joining entity's liabilities | To ensure that the joining entity's liabilities at the joining time, which are part of the joined group's cost of acquiring the joining entity, are reflected in the allocable cost amount |
3 | Add to the result of step 2 the step 3 amount worked out under: (a) section 705 - 90, which is about undistributed, taxed profits accruing to the joined group before the joining time; or (b) if the joining entity is a trust (and not a * corporate tax entity)--section 713 - 25, which is about undistributed, realised profits accruing to the joined group before the joining time that could be distributed tax free | To increase the allocable cost amount: (a) to reflect the undistributed, taxed profits and so prevent double taxation; or (b) if the joining entity is a trust--to reflect the undistributed, realised profits that could be distributed tax free |
3A | For each step 3A amount (if any) under section 705 - 93 (which is about pre - joining time roll - overs): (a) if the step 3A amount is a * deferred roll - over loss--add to the result of step 3 (as affected by any previous application of this step) the step 3A amount; or (b) if the step 3A amount is a * deferred roll - over gain--subtract from the result of step 3 (as affected by any previous application of this step) the step 3A amount | To adjust for certain roll - overs before the joining time affecting deferred gains and losses |
4 | Subtract from the result of step 3A the step 4 amount worked out under section 705 - 95, which is about pre - joining time distributions out of certain profits | To prevent the allocable cost amount reflecting return of part of the amount paid to * acquire the * membership interests in the joining entity |
5 | Subtract from the result of step 4 the step 5 amount worked out under section 705 - 100, which is about certain losses accruing to the joined group before the joining time | To prevent: (a) a double benefit arising from the losses; and (b) losses that cannot be transferred to the * head company, or are cancelled by the head company, under Subdivision 707 - A being reinstated in an unrealised form or reducing unrealised gains. |
5A | Subtract from the result of step 5 the step 5A amount worked out under section 705 - 102, which is about certain * FRT disallowed amounts accruing to the joined group before the joining time | To prevent a double benefit arising from the FRT disallowed amounts |
6 | Subtract from the result of step 5A the step 6 amount worked out under section 705 - 110, which is about losses that the joining entity transferred to the * head company under Subdivision 707 - A | To stop the joined group getting benefits both through higher * tax cost setting amounts for the joining entity's assets and through losses transferred to the head company |
6A | Subtract from the result of step 6 the step 6A amount worked out under section 705 - 112, which is about * FRT disallowed amounts that the joining entity transferred to the * head company under section 820 - 590 | To stop the joined group getting benefits both through higher * tax cost setting amounts for the joining entity's assets and through FRT disallowed amounts transferred to the head company |
7 | Subtract from the result of step 6A the step 7 amount worked out under section 705 - 115, which is about certain deductions to which the * head company is entitled | To stop the joined group getting benefits both through the * tax cost of the joining entity's assets being set and through certain tax deductions of the joining entity being inherited by the head company |
8 | If the remaining amount is positive, it is the joined group's allocable cost amount. Otherwise the joined group's allocable cost amount is nil. |
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Note: The head company may be taken to have made a capital gain, depending on the amount remaining after applying step 3A: see CGT event L2.