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04-Nov-2020 12:18

In addition, if a member enters or leaves the group, certain adjustments to earnings and profits, basis, and other tax attributes apply.Several countries allow related groups of corporations to compute income tax on a consolidated basis, in a manner similar to consolidation for financial reporting purposes.In Australia, fixed trusts and 100% partnerships can be members of a consolidated group, but the head company must be a company and cannot be a trust or partnership.The income tax and credits of the consolidated group are computed as if the group were a single taxpayer. Once a group has elected to file a consolidated return, all members joining the group must participate in the filing.

Both the United States and Australia have rules which restrict the use of such losses in the wider group.

These include the deductions for net operating loss, charitable contributions, domestic production activities deduction, dividends received deduction and others.

Each member of a group must recognize gain or loss on disposition of its shares of other members.

For example, the United Kingdom has a system of group relief, which permits profits of one group company to be reduced by losses of another group company.

Consolidation regimes can include onerous rules and regulations.

Countries which have adopted a tax consolidation regime include the United States, France, Australia and New Zealand.