All income of Tax Group members is included in the Tax Group’s taxable income, unless specified otherwise. This means that any income realized by a Subsidiary must be fully included in the Tax Group’s taxable income (unless eliminated through consolidation), even if the Parent Company does not wholly own the Subsidiary.
Accordingly, if the Parent Company sells shares in a Subsidiary to a third party while maintaining Tax Group status, any resulting capital gain or loss may qualify for the Participation Exemption.
Furthermore , Profit distributions from Subsidiaries to other Tax Group members (such as the Parent Company or other Subsidiaries) should be eliminated in computing the Tax Group’s taxable income.