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FE 31: Worldwide group for corporate excess debt entity if not excess debt outbound company
or “How to determine your worldwide group if you're a company with high debt but not overseas”
You could also call this:

“Defining the global financial group for companies with high overseas debt”

When you’re an excess debt outbound company, you have a worldwide group for each income year. This group includes you, your New Zealand group for that income year, and your worldwide GAAP group.

Your worldwide GAAP group is made up of all non-residents who need to be included with you in consolidated financial statements. These statements are prepared according to generally accepted accounting practice.

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Next up: FE 31C: CFCs in worldwide group for natural persons or trustees described in section FE 2(1)(g)

or “Rules for including overseas companies in worldwide groups for certain individuals and trustees”
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Part F Recharacterisation of certain transactions
Interest apportionment on thin capitalisation: Worldwide group

FE 31BWorldwide group for excess debt outbound companies

  1. For an income year, a worldwide group for an excess debt outbound company is made up of—

  2. the company; and
    1. the company’s New Zealand group for the income year; and
      1. the company’s worldwide GAAP group, as described in subsection (2).

        1. An excess debt outbound company’s worldwide GAAP group is made up of all non-residents who are required to be included with the company in consolidated financial statements under generally accepted accounting practice.

        Notes
        • Section FE 31B: inserted (with effect on 30 June 2009), on , by section 225(1) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34).