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OP 38: Consolidated ICA transfer for net foreign attributed income
or “Removed rule about consolidated imputation group transfers for overseas income”
You could also call this:

“Company in a tax credit-sharing group loses credits for replacement payments made in share-lending deals”

When you’re part of a group of companies that share tax credits, you need to know about something called a replacement payment. This happens when your company borrows shares from someone else and pays them money instead of dividends. If your company adds a tax credit to this payment, your group will lose that same amount of tax credit.

The amount you lose is based on how much tax credit was added to the replacement payment. This rule is listed in a special table that shows all the ways your group can lose tax credits.

The day you make the replacement payment is when your group loses the tax credit. This is important to remember for your group’s tax records.

Remember, this only applies if your company is part of the group when it makes the replacement payment. If you want to know more about how replacement payments work, you can look at section OB 64.

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Next up: OP 40: Consolidated ICA returning share transfer

or “Tax credit reduction for group companies when paying dividends on borrowed shares”
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Part O Memorandum accounts
Memorandum accounts of consolidated groups: Imputation debits of consolidated imputation groups

OP 39Consolidated ICA replacement payment by company under share-lending arrangement

  1. A consolidated imputation group has an imputation debit for the amount of an imputation credit attached under section OB 64 (Replacement payments) to a replacement payment paid under a share-lending arrangement by a company that is part of the consolidated imputation group at the time of payment.

  2. The imputation debit in subsection (1) is referred to in table O20: imputation debits of consolidated imputation groups, row 13 (replacement payment under share-lending arrangement).

  3. The debit date is the day the replacement payment is paid.

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