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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.Thereafter, all corporations that begin to meet the 80% vote and value test must join in the consolidated return.If a subsidiary ceases to meet the 80% vote and value test, it is removed from the group.When these issues are discovered, they may require amending tax returns and could result in tax penalties as well.An affiliated group of corporations that did not file a consolidated return for the immediately preceding tax year may file a consolidated return in lieu of separate returns for the tax year under certain conditions.Tax consolidation, or combined reporting, is a regime adopted in the tax or revenue legislation of a number of countries which treats a group of wholly owned or majority-owned companies and other entities (such as trusts and partnerships) as a single entity for tax purposes.This generally means that the head entity of the group is responsible for all or most of the group's tax obligations (such as paying tax and lodging tax returns).
The final regulations also clarify how members of a controlled group may make the election.
The common parent corporation files returns, and is entitled to make all elections related to tax matters. states permit or require consolidated returns for corporations filing federal consolidated returns.
The common parent acts as agent for the members, and it and the members remain jointly and severally liable for all federal income taxes. Every 80% subsidiary must make the election or it is not valid.
These complex rules require adjustments related to intra-group sales of property (including depreciable assets and inventory), transactions in stock or other obligations of members, performance of services, entry and exit of members, and certain back-to-back and avoidance transactions.
Certain deductions and most credits are computed on a consolidated rather than separate company basis.