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INCOME TAX (TRANSITIONAL PROVISIONS) ACT 1997 - SECT 727.470

Affected interests do not include equity or loan interests owned by entity that is eligible to be an STS taxpayer

             (1)  This section applies to an indirect value shift if:

                     (a)  the indirect value shift happens in the 2007-08 income year or a later income year; and

                     (b)  the scheme that results in the indirect value shift was entered into before the start of the 2007-08 income year.

             (2)  Paragraph 727-470(2)(a) of the Income Tax Assessment Act 1997 (as in force immediately before the commencement of this section) continues to have effect in relation to the indirect value shift as if the repeals and amendments made by Schedule 1, Parts 1 and 2 of Schedule 3 and Schedule 8 to the Tax Laws Amendment (Small Business) Act 2007 had not been made.


Table of Subdivisions

770-A   Transitional foreign losses (common rules)

770-B    Transitional foreign losses (special rules for consolidated groups)

770-C    Transitional foreign losses (special rules for CFCs)

770-D   Transitional foreign income tax offsets (common rules)

770-E    Transitional foreign income tax offsets (special rules for consolidated groups)

Table of sections

Converting an overall foreign loss into a type of tax loss

770-1        Converting a past foreign loss into a tax loss

770-5        Convertible foreign loss

770-10      Reducing an unutilised overall foreign loss amount

Utilising transitional foreign losses

770-15      No special rules if convertible foreign losses total less than or equal to $10,000 or choice made

770-20      Starting total for loss parcel

770-25      Tax loss has foreign loss component

770-30      Deduction limit for foreign loss component

770-35      Offset limit to take account of deducted foreign loss component


Converting an overall foreign loss into a type of tax loss



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