Commentary

B3.414 Transfer of mineral assets within a group

Business tax
Business tax | Commentary

B3.414 Transfer of mineral assets within a group

Business tax | Commentary

B3.414 Transfer of mineral assets within a group

Provisions1 are made to deal with transfers of mineral assets between companies within a group, ie where the transferor company controls or is controlled by the transferee company or where both are controlled by a third party2.

The provisions do not apply3:

  1.  

    (a)     where there is an election to treat the sale as being at an alternative amount (see B3.108); or

  2.  

    (b)     where the mineral asset is an oil licence (see B3.413).

With those exceptions, any expenditure incurred by the transferee company on the transferred asset in excess of the transferor company's expenditure on

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