Draft Taxation Ruling on application of "same business test" to tax consolidated groups

The Australian Taxation Office released for discussion Draft Taxation Ruling on the application of the same business test (SBT) to tax consolidated and multiple entry consolidated (MEC) groups.

By way of background, wholly-owned groups may elect to form tax consolidated or MEC groups. Tax consolidation allows such groups to be treated as a single taxpayer, ignore intra-group transactions for income tax purposes, and treat subsidiaries of the head company as par…