A2M Income Tax, page-8

I believe this issue comes about because A2M US and UK are separate entities (though wholly owned by A2MC the AU/NZ entity).

A2MC charges the US and UK companies for various costs such as IP licence, marketing and corporate support costs.

These are done through intercompany charges. It results in A2MC booking income due to these charges. However it also results in loading the US and UK entities with more costs on top of their local costs of producing milk and marketing, wages etc.

So they end up with bigger losses. These losses cannot be claimed by A2MC as they are incurred by an overseas entity. In the meantime A2MC have to pay tax on on the income they received from the US and UK entities.

Down the track when US and UK start earning genuine profits, they won't pay tax until they clear these previous tax losses. So it's mainly a cash flow issue atm and unfortunately detracts from genuine NPAT.