Section FM 6 — Income Tax Act 2007: Some general rules for treatment of consolidated groups

FM 6 Some general rules for treatment of consolidated groups References to income, tax losses, tax payable, and credits (1) For the purposes of the consolidation rules, the following amounts are determined on the basis of a single assessment: (a) income, assessable income, net income, or taxable income of a consolidated group: (b) a tax loss component, a tax loss, a loss balance, an attributed CFC net loss, or a FIF net loss of a consolidated group: (c) tax payable by a consolidated group: (d) a tax credit available to a consolidated group. Shares (2) For the purposes of applying the consolidation rules to particular provisions in this Act, the shares or options over shares of a consolidated group are treated as comprising all the shares or options over shares of the companies in the consolidated group at the relevant time. Dividends (3) A dividend that 1 company that is part of a consolidated group pays to another group company continues to be taken into account for the purposes of— (a) the imputation rules: (b) [Repealed] (c) sections FM 8(3)(c) , FM 27 to FM 30 , GB 38 , and OP 3 to OP 50 (which relate to dividends and consolidated groups): (d) [Repealed] (e) section 74 of the Tax Administration Act 1994. International tax rules (4) The international tax rules apply, modified as necessary, as if the consolidated group were a single company. Balance of imputation credit account (5) Sections OA 3 (General rules for maintaining memorandum accounts) and YA 2(7) (Meaning of income tax varied) apply for the purposes of section GB 38 , subpart OP , and section 74 of the Tax Administration Act 1994 as if the references to the imputation rules were references to sections OP 3 to OP 50 . Defined in this Act: amount , assessable income , assessment , attributed CFC net loss , company , consolidated group , consolidation rules , dividend , FIF net loss , imputation credit account , imputation rules , income , income tax , international tax rules , loss balance , net income , pay , share , tax , tax credit , tax loss , tax loss component , taxable income , Compare: 2004 No 35 ss FD 2 , FD 11 Section FM 6(3)(b): repealed (with effect on 30 June 2009), on 6 October 2009, by section 230(1) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34). Section FM 6(3)(c): substituted (with effect on 30 June 2009), on 6 October 2009, by section 230(2) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34). Section FM 6(3)(c): amended (with effect on 1 July 2012), on 2 November 2012 (applying for income years beginning on or after 1 July 2012), by section 71(1) of the Taxation (Annual Rates, Returns Filing, and Remedial Matters) Act 2012 (2012 No 88). Section FM 6(3)(d): repealed, on 1 July 2012 (applying for income years beginning on or after that date), by section 66(1) of the Taxation (International Investment and Remedial Matters) Act 2012 (2012 No 34). Section FM 6(3)(e): substituted (with effect on 30 June 2009), on 6 October 2009, by section 230(3) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34). Section FM 6(5) heading: substituted (with effect on 30 June 2009), on 6 October 2009, by section 230(5) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34). Section FM 6(5): substituted (with effect on 30 June 2009), on 6 October 2009, by section 230(5) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34). Section FM 6 list of defined terms FDP account : repealed (with effect on 30 June 2009), on 6 October 2009, by section 230(6) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34). Section FM 6 list of defined terms FDP rules : repealed (with effect on 30 June 2009), on 6 October 2009, by section 230(6) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34).