Last year, the Tax Laws Amendment (2012 Measures No 2) Act 2012 modified the consolidation rights to future income (RTFI) and residual tax cost setting (RTCS) rules. The changes were intended to ensure that the tax outcomes for consolidated groups are more consistent with the tax outcomes that arise when assets are acquired outside the consolidation regime.
The ATO says that, in recent months, it has worked with some consolidated groups to review their RTFI and RTCS claims in light of these changes. According to the ATO, “to maintain fair and equitable treatment of large business taxpayers”, it is:
- identifying claims for RTFI and RTCS expenditure that may no longer be deductible;
- undertaking compliance assurance within the specially extended legislative amendment period ending on 29 June 2014.
The ATO says that new information is now available on its website to help consolidated groups review past claims.
[LTN 77, 24/4/13]