Date
- 1922-1934
- Preceding 4 years of losses can be deducted against income (including exempt income) in the order they occurred.
- 1944
- COT introduced for private companies, no loss will be an allowable deduction unless 25 per cent of the shares were held by the same person at both the time the loss was made and the time of deduction.
- 1947
- Carry forward period of 7 years introduced for primary producers.
- 1950
- 7 year carry forward rule extended to all private companies.
- 1964
- COT rules extended to public companies. COT threshold increased to not less than 40 per cent beneficial ownership based on voting power, rights to dividends and rights to capital and applied to ALL companies.
- 1965
- SBT introduced as a concession where there is a COT failure.
- 1966
- The limit of seven years on the carry-forward period for deductions of prior year losses is removed for primary producers.
- 1973
- COT threshold increased to more than 50 per cent beneficial ownership.
- 1973
- A control test and income injection test introduced to add integrity to COT. The COT and SBT are extended to apply to the utilisation of bad debts.
- 1984
- Group loss transfers introduced. Advent of consolidation saw the scope of these provisions greatly reduced.
- 1985
- CGT introduced. COT and SBT must be satisfied to apply prior year capital losses.
- 1986
- Foreign losses no longer offsettable against Australian income, domestic losses no longer offsettable against foreign income.
- 1990
- Unlimited carry-forward losses introduced.
- 1995
- Trust loss rules take effect. Trust loss rules do not apply to the recoupment of net capital losses.
- 1997
- Modifications made to COT to make it easier for certain public companies to recoup losses - Division 166.
- 1999
- As a precursor to consolidation, 'Business Tax Reform' introduces a series of integrity rules to strengthen COT and reduce the opportunity for capital loss creation.
- 2002
- Consolidation introduced. Measures included loss transfer rules, modifications to COT and SBT and recoupment restrictions, and available fraction test. Normal COT and SBT apply following transfer of the loss into consolidated group.