All companies forming the imputation group must be wholly-owned. They must also be eligible to be part of an imputation group.
What the eligibility criteria is
All companies wanting to form an imputation group must meet all the following criteria:
- It is a tax resident in New Zealand or Australia and is not treated as resident in another country for the purposes of a double tax agreement (DTA).
- It maintains an imputation credit account.
- It is not a qualifying company unless all members are qualifying companies.
- It is not a mining company unless all members are mining companies.
- It is not a member of a consolidated group unless all members of the consolidated group meet all the above criteria. All members of the consolidated group must also elect to be members of the imputation group.
- Members from more than one consolidated group may only be part of an imputation group if the existing credits in the consolidated imputation accounts have the same shareholder continuity profile.
- There must be no arrangement to defeat the intent and application of the imputation rules.