Part 3 - 6 operates as if a * frankable distribution made by a * subsidiary member of a * consolidated group (the foreign - held subsidiary ) were a frankable distribution made by the * head company of the group to a * member of the head company if:
(a) the foreign - held subsidiary meets the set of requirements in section 703 - 45, section 701C - 10 of the Income Tax (Transitional Provisions) Act 1997 or section 701C - 15 of that Act; and
(b) the frankable distribution is made to a foreign resident.
Note: Part 3 - 6 deals with imputation.