:- module('one+https://www.ato.gov.au/general/capital-gains-tax/small-business-cgt-concessions/small-business-restructure-rollover',[]).
mainGoal(event_of_transfering_from_to_at_occurs(_ID,_Asset,_Transferor,_TransfereesList,_When), "Determine if a asset transfer event can be treated as a restructure rollover").
%is_after(20200702,20160701).
example( 'Testing scenario', [
% initial facts and condition:
scenario([event_of_transfering_from_to_at_occurs(123,company1_goodwill,company1,[miguel], 20160701),
is_after(20160701,20160701),
is_immediately_before(20160630, 20160701),
has_of_according_to_other_legislation(miguel,aggregated, 400000),
has_of_according_to_other_legislation(company1,aggregated, 5300000)], applies(123))
]).
example( 'Ultimate ownership unchanged', [
% initial facts and condition:
scenario(['penny runs a business B','B has assets A'], is_ultimately_owned_by(A,'Penny',1)),
% new facts and condition:
scenario(['penny has trust T', transfer_event(_ID,_A,_When,_B,[_T])], is_ultimately_owned_by(A,'Penny'))
]).
example( 'Changed share of ownership', [
% initial facts and condition:
scenario(['Amy, Joanna and Remy run a delivery business B as equal partners','B has assets A'],
true),
% new facts and condition:
scenario(['Amy, Joanna and Remy establish company C, different shares', transfer_event(ID,_A,_When,_B,[_C])],
not applies(ID)),
% alternative facts and another condition:
scenario(['Amy, Joanna and Remy establish company C, different shares', 'Amy, Joanna and Remy establish company C, equal shares'],
applies(ID))
]).
example( 'Andrew email Feb 4 2021', [
/* Company transfers its assets to partners in a partnership on 1 July 2020. Company has turnover of 5,300,000.
Company is a Small Business Entity i.e. the transferor & the partners in a partnership i.e. transferee is also a small business entity.)
Assets are - Goodwill, Trading stock, Plant & equipment, revenue assets
*/
scenario([
owns_at_according_to_other_legislation(company1,company1_goodwill, T) at BASICS if T @=< BEFORE,
owns_at_according_to_other_legislation(company1,company1_trading_stock, T) at BASICS if T @=< BEFORE,
owns_at_according_to_other_legislation(company1,company1_plant_and_equipment, T) at BASICS if T @=< BEFORE,
owns_at_according_to_other_legislation(company1,company1_revenue_asset,T) at BASICS if T @=< BEFORE,
%TODO: add time here, and below...?
is_a_partner_in_partnership_with_according_to_other_legislation(andrew,company1) at BASICS, is_a_partner_in_partnership_with_according_to_other_legislation(miguel,company1) at BASICS,
has_of_according_to_other_legislation(company1,_, 5300000) at AGGREGATION,
has_of_according_to_other_legislation(andrew,_, 1000000) at AGGREGATION,
has_of_according_to_other_legislation(miguel,_, 500000) at AGGREGATION,
is_a_small_business_entity_according_to_other_legislation(company1) at SBE, is_a_small_business_entity_according_to_other_legislation(andrew) at SBE, is_a_small_business_entity_according_to_other_legislation(miguel) at SBE,
event_of_transfering_from_to_at_occurs(EVENT,company1_goodwill,company1,[andrew,miguel], WHEN),
% with the rule as it is below, no point in injecting more than one event:
%transfer_event(EVENT2,company1_trading_stock,WHEN,company1,[andrew,miguel]),
%transfer_event(EVENT3,company1_plant_and_equipment,WHEN,company1,[andrew,miguel]),
%transfer_event(EVENT4,company1_revenue_asset,WHEN,company1,[andrew,miguel]),
owns_at_according_to_other_legislation(company1,company1_goodwill, T) at BASICS if T @>= WHEN,
owns_at_according_to_other_legislation(company1,company1_trading_stock, T) at BASICS if T @>= WHEN,
owns_at_according_to_other_legislation(company1,company1_plant_and_equipment, T) at BASICS if T @>= WHEN,
owns_at_according_to_other_legislation(company1,company1_revenue_asset,T) at BASICS if T @>= WHEN,
is_part_of_genuine_restructuring_according_to_other_legislation(EVENT) at "https://www.ato.gov.au/law/view/document?DocID=COG/LCG20163/NAT/ATO/00001&PiT=99991231235958",
is_used_in_business_of_according_to_other_legislation(company1_goodwill,company1) at BASICS,
is_of_asset_type_according_to_other_legislation(company1_goodwill,trading_stock) at myDb17,
is_the_trust_of(_,_) if false
| MoreFacts
], applies(EVENT))
]) :-
% for mere convenience, Prolog code to setup some data and make the above less cluttered:
EVENT=123,
WHEN='20200701', is_immediately_before(BEFORE,WHEN),
SBE= "https://www.ato.gov.au/General/Capital-gains-tax/Small-business-CGT-concessions/Basic-conditions-for-the-small-business-CGT-concessions/Small-business-entity/",
BASICS="https://www.ato.gov.au/general/capital-gains-tax/small-business-cgt-concessions/basic-conditions-for-the-small-business-cgt-concessions/",
AGGREGATION="https://www.ato.gov.au/business/small-business-entity-concessions/eligibility/aggregation/",
findall(is_a_small_business_entity_according_to_other_legislation(E) at SBE, member(E,[company1,andrew,miguel]), MoreFacts).
example( 'Andrew email Feb 4 2021 version 2', [
/* Company transfers its assets to partners in a partnership on 1 July 2020. Company has turnover of 5,300,000.
Company is a Small Business Entity i.e. the transferor & the partners in a partnership i.e. transferee is also a small business entity.)
Assets are - Goodwill, Trading stock, Plant & equipment, revenue assets
*/
scenario([
%owns_at_according_to_other_legislation(company1,company1_goodwill, T) at BASICS if T @=< BEFORE,
%owns_at_according_to_other_legislation(company1,company1_trading_stock, T) at BASICS if T @=< BEFORE,
%owns_at_according_to_other_legislation(company1,company1_plant_and_equipment, T) at BASICS if T @=< BEFORE,
%owns_at_according_to_other_legislation(company1,company1_revenue_asset,T) at BASICS if T @=< BEFORE,
%TODO: add time here, and below...?
%is_a_partner_in_partnership_with_according_to_other_legislation(andrew,company1), is_a_partner_in_partnership_with_according_to_other_legislation(miguel,company1),
has_of_according_to_other_legislation(company1,_, 5300000),
has_of_according_to_other_legislation(andrew,_, 1000000),
has_of_according_to_other_legislation(miguel,_, 500000),
%is_a_small_business_entity_according_to_other_legislation(company1) at SBE, is_a_small_business_entity_according_to_other_legislation(andrew) at SBE, is_a_small_business_entity_according_to_other_legislation(miguel) at SBE,
event_of_transfering_from_to_at_occurs(EVENT,company1_goodwill,company1,[andrew,miguel], WHEN)
% with the rule as it is below, no point in injecting more than one event:
%transfer_event(EVENT2,company1_trading_stock,WHEN,company1,[andrew,miguel]),
%transfer_event(EVENT3,company1_plant_and_equipment,WHEN,company1,[andrew,miguel]),
%transfer_event(EVENT4,company1_revenue_asset,WHEN,company1,[andrew,miguel]),
%owns_at_according_to_other_legislation(company1,company1_goodwill, T) at BASICS if T @>= WHEN,
%owns_at_according_to_other_legislation(company1,company1_trading_stock, T) at BASICS if T @>= WHEN,
%owns_at_according_to_other_legislation(company1,company1_plant_and_equipment, T) at BASICS if T @>= WHEN,
%owns_at_according_to_other_legislation(company1,company1_revenue_asset,T) at BASICS if T @>= WHEN,
%is_part_of_genuine_restructuring_according_to_other_legislation(EVENT) at "https://www.ato.gov.au/law/view/document?DocID=COG/LCG20163/NAT/ATO/00001&PiT=99991231235958",
%is_used_in_business_of_according_to_other_legislation(company1_goodwill,company1) at BASICS,
%is_of_asset_type_according_to_other_legislation(company1_goodwill,trading_stock) at myDb17,
%is_the_trust_of(_,_) if false
| MoreFacts
], applies(EVENT))
]) :-
% for mere convenience, Prolog code to setup some data and make the above less cluttered:
EVENT=123,
%WHEN='20200701', is_immediately_before(BEFORE,WHEN),
SBE= "https://www.ato.gov.au/General/Capital-gains-tax/Small-business-CGT-concessions/Basic-conditions-for-the-small-business-CGT-concessions/Small-business-entity/",
BASICS="https://www.ato.gov.au/general/capital-gains-tax/small-business-cgt-concessions/basic-conditions-for-the-small-business-cgt-concessions/",
AGGREGATION="https://www.ato.gov.au/business/small-business-entity-concessions/eligibility/aggregation/",
findall(is_a_small_business_entity_according_to_other_legislation(E) at SBE, member(E,[company1,andrew,miguel]), MoreFacts).
is_immediately_before(20200630,20200701).
en("the templates are:
A trust 's election ocurred,
A trust is the trust of a group,
An Event ID rollover applies,
An owner / a share,
An Event ID rollover of the transfer of an Asset from a Transferor to a Transferees List at a Time applies,
event an event of transfering an asset from a payer to a recipient at a time occurs,
the small business restructure rollover applies to an event,
an asset is an eligible asset,
an event occurs at a time,
an event is a transfer of an asset by a transferor to a transferee,
an event is part of genuine restructuring according to other legislation,
an event meets the ultimate ownership test at a time,
an event is undertaken as part of a trust,
a trust relates to a family group,
an individual is a member of a group,
an individual is an ultimate owner of an asset at a time,
a trust is a family trust,
a thing is of type a type,
a tax payer is in a transferee,
a time is after a second time,
a party is a party of an event,
an amount is the aggregated turnover of a party,
a party is an eligible party,
a previous time is immediately before a time,
an asset is ultimately owned by a share with an owner at a time,
an entity has a share in an asset at a time,
an owner owns an asset at a time according to other legislation,
a party is a small business entity according to other legislation,
a party has affiliated with an affiliate according to other legislation,
a party is connected to a taxpayer according to other legislation,
a party is a partner in partnership with a partnership according to other legislation,
an asset is an active asset,
an asset is used in business of a taxpayer according to other legislation,
an asset is of asset type a type,
an asset is of asset type a type according to other legislation,
a party has an aggregated turnover of an amount,
a party has an aggregated turnover of an amount according to other legislation,
a cost is a rollover cost,
an asset costs a cost at a time,
an owner / a thing is in a set.
the knowledge base includes:
An Event ID rollover of the transfer of an Asset from a Transferor to a Transferees List at a Time applies
if this information transfer_event(the Event ID,the Asset,the Time,the Transferor,the Transferees List) has been recorded
and the Event ID rollover applies.
cgt_asset is of type asset.
trading_stock is of type asset.
revenue_asset is of type asset.
depreciating_asset is of type asset.
loan_to_shareholder is of type asset.
A tax payer is a party of an event
if event the event of transfering an asset from the tax payer to a recipient at a time occurs.
A tax payer is a party of an event
if event the event of transfering an asset from a somebody to a transferee at a time occurs
and the tax payer is in the transferee.
An event rollover applies
if event the event of transfering an asset from a sender to a recipient at a time occurs
and the time is after 20160701
and for all cases in which
a party is a party of the event
it is the case that:
the party has an aggregated turnover of a turnover
and the turnover < 10000000
and the party is an eligible party
and the event is part of genuine restructuring according to other legislation
and a previous time is immediately before the time
and a set previous owners is a collection of an owner / a share
where the asset is ultimately owned by the share with the owner at the previous time
and a set new owners is a collection of the owner / the share
where the asset is ultimately owned by the share with the owner at the time
and the set new owners = the set previous owners
or a family trust is the trust of a group
and the family trust 's election ocurred
and for all cases in which
the owner / le_some_thing is in the set previous owners
it is the case that:
the owner is in the group
and for all cases in which
the owner / le_some_thing is in the set new owners
it is the case that:
the owner is in the group
and the asset is an eligible asset.
the small business restructure rollover applies to an event
if the event occurs at a time
and the time is after 20160701
and the event is a transfer of an asset by a transferor to a transferee
and the asset is an eligible asset
and the event is part of genuine restructuring according to other legislation
and the event meets the ultimate ownership test at the time
and for all cases in which
a party is a party of the event
and an amount is the aggregated turnover of the party
it is the case that:
the party is an eligible party
and the amount < 10000000.
an event meets the ultimate ownership test at a time
if the event is a transfer of an asset by a transferor to a transferee
and a previous time is immediately before the time
and for all cases in which
the entity is an ultimate owner of the asset at the time
and the entity has a share in the asset at the time
it is the case that:
the entity is an ultimate owner of the asset at the previous time
and the entity has the share in the asset at the previous time.
an event meets the ultimate ownership test at a time
if the event is a transfer of an asset by a transferor to a transferee
and the event is undertaken as part of a trust
and the trust is a family trust
and the trust relates to a family group
and a previous time is immediately before the time
and for all cases in which
an individual is an ultimate owner of the asset at the time
it is the case that:
the individual is a member of the family group
and for all cases in which
an individual is an ultimate owner of the asset at the previous time
it is the case that:
the individual is a member of the family group.
An asset is ultimately owned by 1 with an owner at a time
if the owner owns the asset at the time according to other legislation.
A party is an eligible party
if the party is a small business entity according to other legislation.
A party is an eligible party
if the party has affiliated with an affiliate according to other legislation
and the affiliate is a small business entity according to other legislation.
A party is an eligible party
if the party is connected to a taxpayer according to other legislation
and the taxpayer is a small business entity according to other legislation.
A party is an eligible party
if the party is a partner in partnership with a partnership according to other legislation
and the partnership is a small business entity according to other legislation.
An asset is an eligible asset
if the asset is an active asset
and the asset is of asset type a type
and the type is in [cgt_event,depreciating_asset,trading_stock,revenue_asset].
An asset is an active asset
if the asset is used in business of a taxpayer according to other legislation.
An asset is of asset type a type
if the type is of type asset
and the asset is of asset type the type according to other legislation.
A party has an aggregated turnover of an amount
if the party has an aggregated turnover of the amount according to other legislation.
A cost is a rollover cost
if the event occurs at a time
and the event is a transfer of an asset by a transferor to a transferee
and a previous time is immediately before the time
and the asset costs the cost at the previous time.").
/** <examples>.
?- le(LogicalEnglish).
?- query_with_facts(applies(Event),'Testing scenario',Unknowns,Explanation,Result).
?- query_with_facts(applies(Event),'Andrew email Feb 4 2021 version 2',Unknowns,Explanation,Result).
*/