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Issue: IQ 1 and IQ 2, IA 2(5), IA 7, IA 7(5), IE 3(1) and IE 1

Submission Number 90
Submitter Deloitte

Section / Provision Income Tax Act 2007

IQ 1 and IQ 2, IA 2(5), IA 7, IA 7(5)

Section / Provision Income Tax Act 2004

IE 3(1) and IE 1

Date Received

15/10/08
Description of issue

The ability to carry forward an attributed CFC net loss is in doubt as the general rules do not appear to apply.

Section / Provision Income Tax Act 1994

IE 3(1) and IE 1

Status Finalised
Outcome The Panel considers on balance no unintended legislative change arises in respect of section IQ 1 and subpart IA of the Income Tax Act 2007.

Refer to Policy Advice Division to consider retrospective clarification of the Income Tax Act 2007.


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