Table of Subdivisions
195-A Pooled development funds (PDFs)
Subdivision 195-A—Pooled development funds (PDFs)
195-1 What this Subdivision is about
This Division contains rules about the income tax treatment of:
· pooled development funds (PDFs)
· shares in PDFs.
Table of sections
Working out a PDF’s taxable income and tax loss
195-5 Deductibility of PDF tax losses
195-10 PDF cannot transfer tax loss
195-15 Tax loss for year in which company becomes a PDF
Working out a PDF’s taxable income and tax loss
195-5 Deductibility of PDF tax losses
If a company is a *PDF at the end of an income year for which it has a *tax loss, it can deduct the tax loss in a later income year only if it is a PDF throughout the later income year.
195-10 PDF cannot transfer tax loss
If a company is a *PDF at the end of an income year for which it has a *tax loss, it cannot transfer any amount of the tax loss under Subdivision 170-A (which is about the transfer of tax losses within wholly-owned groups of companies).
195-15 Tax loss for year in which company becomes a PDF
(1) This section applies if a company becomes a *PDF during an income year and is still a PDF at the end of it.
(2) Divide the income year into periods as follows:
(a) the non-PDF period is the period beginning at the start of the income year and ending when the company becomes a *PDF;
(b) the PDF period is the rest of the income year.
(3) For each period, work out whether the company has a taxable income or a *tax loss (or both), treating each period as if it were an income year.
(4) If the company has:
(a) a taxable income for the non-PDF period; and
(b) a *tax loss for the PDF period;
that tax loss is a tax loss of the company for the income year.
Note: The company can only deduct the tax loss while it is a PDF: see section 195-5.
(5) If the company has a *tax loss for the non-PDF period:
(a) section 195-5 does not prevent the company from deducting its tax loss for the income year in a later income year; and
(b) section 195-10 does not prevent the company from transferring an amount of the tax loss under Subdivision 170-A (which is about the transfer of tax losses within wholly-owned groups of companies);
to the extent that the tax loss does not exceed the tax loss for the non-PDF period.
(6) These rules apply in addition to the other rules about how *tax losses are applied or transferred.
The other rules start in Division 36 (which is about tax losses
of earlier income years).
[The next Part is Part 3-45.]