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May 15, 2026
This article outlines the mechanics of calculating a Tax Group's Taxable Income. The Parent Company must prepare consolidated financial statements, eliminating all transactions between group members. Specific rules apply to tax losses: pre-grouping losses of a joining subsidiary can only be used against income attributable to that same subsidiary (loss streaming). Likewise, existing group losses cannot offset income from a new subsidiary. If an asset is transferred within the group and a member leaves within two years, the initial tax-neutral treatment is reversed, and the gain or loss is recognised.
Chapter 12 - Tax Group Provisions
Article 42 - Taxable Income of a Tax Group
[GTL Notes]
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