The main object of this Subdivision is to avoid double taxation by transferring from the * head company of a * consolidated group to a company (the leaving company ) that ceases to be a * subsidiary member of the group at a time (the leaving time ) the benefit of each of these surpluses (to the extent that each surplus can be attributed to the leaving company):
(a) the attribution surplus (if any) for an attribution account entity (within the meaning of Part X of the Income Tax Assessment Act 1936 ) in relation to the head company just before the leaving time;
(b) the post FIF abolition surplus (if any) (within the meaning of the Income Tax Assessment Act 1936 ) for a FIF attribution account entity (within the meaning of former Part XI of that Act) in relation to the head company just before the leaving time.