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Income Tax Act 2007

Recharacterisation of certain transactions - Imputation groups of companies

FN 8: Trans-Tasman imputation groups and resident imputation subgroups

You could also call this:

“Rules for tax groups with both Australian and New Zealand companies”

When a group of companies has at least one Australian ICA company and at least one non-Australian ICA company, you call this group a trans-Tasman imputation group.

If you’re a company in this trans-Tasman imputation group and you’re not an Australian ICA company, you’re part of what’s called a resident imputation subgroup. This subgroup is connected to the main trans-Tasman imputation group.

The resident imputation subgroup keeps going as long as there’s at least one company in the trans-Tasman imputation group that isn’t an Australian ICA company and is still operating.

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View the original legislation for this page at https://legislation.govt.nz/act/public/1986/0120/latest/link.aspx?id=DLM1516761.

Topics:

Money and consumer rights > Taxes

FN 7: Forming imputation groups, or

“How companies can group together for tax purposes”

FN 9: Joining existing imputation group, or

“How to join an existing group for tax credits”

Part F Recharacterisation of certain transactions
Imputation groups of companies

FN 8Trans-Tasman imputation groups and resident imputation subgroups

If at least 1 company in an imputation group is an Australian ICA company, and at least 1 company in the imputation group is not an Australian ICA company, the imputation group is a trans-Tasman imputation group.
A company in a trans-Tasman imputation group that is not an Australian ICA company is treated as a resident imputation subgroup of the trans-Tasman imputation group and is associated with that group.
A resident imputation subgroup continues while a company in the trans-Tasman imputation group that is not an Australian ICA company remains in existence.

Compare

2004 No 35 ss FDA 3(1), (3), OB 1 resident imputation subgroup, trans-Tasman imputation group

Notes

Section FN 8(2): substituted (with effect on 1 April 2008), on 6 October 2009, by section 234(1) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34).
Section FN 8(3) heading: substituted (with effect on 1 April 2008), on 6 October 2009, by section 234(2) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34).
Section FN 8(3): substituted (with effect on 1 April 2008), on 6 October 2009, by section 234(2) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34).