Commonwealth Consolidated ActsWork 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 section 705‑90, which is about undistributed, frankable profits accruing to the joined group before the joining time | To increase the allocable cost amount to reflect the undistributed, taxed profits and so prevent double taxation |
| 4 | Subtract from the result of step 3 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. |
| 6 | Subtract from the result of step 5 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 |
| 7 | Subtract from the result of step 6 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. |
|