Ivy was an "associate" (like a wife is an "associate" of a husband) and not a "subsidiary". A wife cannot assume the tax losses of a husband. They are separate entities. Further:
22. Subsidiaries The consolidated financial statements include the assets, liabilities and results of the following subsidiaries: Name of Entity Country of Equity Type Holding Holding Incorporation 2018 2017 % % Chimpchange LLC US Membership units 100 100 Change Labs NZ Pty Ltd Australia Ordinary Shares 100 100
Associates are those entities over which the Group is able to exert significant influence but which are not subsidiaries.
INCOME TAX ASSESSMENT ACT 1936 - SECT 318
(e) a company where: (i) the company is sufficiently influenced by: (A) the primary entity; or
etc
http://classic.austlii.edu.au/au/legis/cth/consol_act/itaa1936240/s318.html
Ann: Finalisation of Ivy Project divestment, page-21
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