The main object of this Subdivision is to avoid double taxation by transferring from a company (the joining company ) that becomes a * subsidiary member of a * consolidated group at a time (the joining time ) to the * head company of the group the benefit of each of these:
(a) the attribution surplus (if any) for an attribution account entity (within the meaning of Part X of the Income Tax Assessment Act 1936 ) in relation to the joining company just before the joining time;
(b) the post FIF abolition surplus (if any) (within the meaning
of the Income Tax Assessment Act 1936 ) for a FIF attribution account entity
(within the meaning of former Part XI of that Act) in relation to the
joining company just before the joining time.