All companies forming the imputation group must be wholly-owned. They must also be eligible to be part of an imputation group.
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.