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TD 2004/85 - Income tax: can Division 16E of Part III of the Income Tax Assessment Act 1936 apply to a head Co of a consolidated group where an intra-group income stream is assigned by a member of the group to a non-member?

[2004] ATOTD 85

Australian Taxation Office

Australia - Commonwealth

Legislation Cited

Legislation Name	Provision
Income Tax Assessment Act 1936 (Cth)	s159GP
Income Tax Assessment Act 1997 (Cth)	s70.1
Taxation Administration Act 1953 (Cth)

Cases and Articles Cited

Case Name	Citation(s)	Court †	Jurisdiction	Date	Full Text		Citation Index
Re Southern Brazilian Rio Grande Do Sul Railway Co Ltd	[1905] UKLawRpCh 57; (1905) 2 Ch 78	Court of Chancery	United Kingdom	15 Apr 1905	CommonLII		9
FCT v Firth	(2002) 120 FCR 450	Federal Court of Australia	Australia	circa 2002	Legal Online / Westlaw		38
Re Farm Security Act 1944 of the Province of Saskatchewan	[1947] SCR 394			circa 1947			25
Commissioner of Taxation v Firth	(2002) 50 ATR 1; [2002] FCA 413; 192 ALR 542; (2002) 120 FCR 450		Australia	circa 2002	Legal Online / Westlaw		18

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