http://en.wikipedia.org/wiki/Tax_consolidation
Tax consolidation
From Wikipedia, the free encyclopedia
Tax consolidation 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 aim of a tax consolidation regime is to reduce administrative costs for government revenue departments and reduce compliance costs for corporate taxpayers. However, consolidation regimes can include onerous rules and regulations.
Countries which have adopted a tax consolidation regime include the United States, Australia and New Zealand.
There are four main reasons for consolidating. First if there are losses in the group companies which you wish to absorb. Second if there are dividends you wish to declare but do not have sufficient imputation credits in the particular company. Third if there are assets that you wish to transfer between companies without triggering capital gains tax. Fourth if you have bought shares in a subsidiary instead of the assets of the business, and wish to name the assets of the company so that depreciation can be calculated thereon.
Consolidation is an all or nothing event - once decision to consolidate has been made, companies are irrevocably bound, and only by having a less than 100% interest in a subsidiary, can it be left out of the consolidation.
When subsidiaries are bought for share value rather than outright purchsse of assets, a regime called allocalbe cost amount is in force to tranform the amount paid for the shares into depreciable and other assets. Likewise when a company is sold for the value of its shares, the reverse of allocable cost amount takes place to extract the assets from the consolidation.
Current losses have no problem in being absorbed by current profits in the other companies but losses brought in to the consolidation can pose a problem for amount allowed to be written off in each year, called the available fraction. The reason for this is otherwise companies with big losses could be bought to offset current tax liabilities, and there is a calculation based on the overall size of the group and the size of the purchased loss, to limit the amount that can be written off each year. That is not to say that the whole loss might not be allowed, it will, but only a percentage of it can be written off each year.
In a consolidation all inmputation credits and losses float to the top company, and there is no need to declare individual dividends from the discrete companies in order for the head company to pay franked dividends, and only one dividend is declared which is from the head company.
Fixed trusts and 100% partnerships can be members of a consolidated group, but the head company must be company and cannot be a trust or partnership.
Реформа налогообложения в Японии 2002
http://unpan1.un.org/intradoc/groups/pu ... 018834.pdf
How does the consolidated (national) taxation regime affect
the local tax calculation ?
http://www.pwc.com/Extweb/pwcpublicatio ... 5_02_e.pdf
Federal income taxation of corporations filing consolidated returns.
by Herbert J Lerner; Matthew Bender (Firm)
Language: English Type: Book
Publisher: New York : M. Bender, 1975
Tax Consolidation Rules Implemented (Italy 2004)
http://www.deloitte.com/dtt/cda/doc/con ... 060704.pdf
The Consolidated Tax Return (Думаю, одна из лучших)
http://ria.thomson.com/estore/detail.as ... f+Contents
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