Commonwealth Consolidated Acts Commonwealth Consolidated ActsThis section imposes a tax that is payable under section 45 - 25 of the Income Tax Assessment Act 1997 by a company that was a member of the wholly - owned group referred to in that section just before the time when the direct or indirect beneficial ownership referred to in paragraph 45 - 15(1)(f) or 45 - 20(1)(f) of that Act was acquired.