1   Head company

The entity must be a company (but not one covered by section   703 - 20) that has all or some of its taxable income (if any) taxed at a rate that is or equals the * corporate tax rate

The entity must be an Australian resident (but not a * prescribed dual resident)

The entity must not be a * wholly - owned subsidiary of another entity that meets the requirements in columns 2 and 3 of this item or, if it is, it must not be a subsidiary member of a * consolidatable group or * consolidated group

2   Subsidiary member

The requirements are that:

(a) the entity must be a company, trust or partnership (but not one covered by section   703 - 20); and

(b) if the entity is a company--all or some of its taxable income (if any) must be taxable apart from this Part at a rate that is or equals the * corporate tax rate; and

(c) the entity must not be a non - profit company (as defined in the Income Tax Rates Act 1986 )

The entity must:

(a) be an Australian resident (but not a * prescribed dual resident), if it is a company; or

(b) comply with section   703 - 25, if it is a trust; or

(c) be a partnership

The entity must be a * wholly - owned subsidiary of the head company of the group and, if there are interposed between them any entities, the set of requirements in section   703 - 45, section   701C - 10 of the Income Tax (Transitional Provisions) Act 1997 or section   701C - 15 of that Act must be met