Banked versus Bankable . . ., page-7

Thanks for that kids - I don't pretend to know tax but it's good to know of potential issues. I knew there was commonality requirements and a quick check shows that subvention payments can only be made if commonality is set at 2/3's ownership.

Bathurst owns 65% of BT meaning losses might struggle to be offset? Bathurst may have to increase their stake...


"A company that has at least 66 percent of shareholders the same as another company is referred to as being “commonly-owned”. A company (“the loss company”) can transfer the benefit of a loss incurred to a commonly-owned company (“the profit company”) by undertaking a loss offset or receiving a subvention payment (“a loss transfer”)."

http://taxpolicy.ird.govt.nz/publications/2016-ris-archcrm-bill/loss-grouping-and-imputation-credits