Published on 24 May 07
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper is a non-exhaustive journey through some of the traps embedded in the Consolidations regime and suggestions about dealing with them, including:
using a consolidated group as a bid vehicle
bad and doubtful debts of a joining entity - a legislative botch-up
deferred tax liabilities - complex on joining and double tax on exit
over-depreciation adjustment - it can apply again and again and again
the unrealised loss rules - three choices, but they’re a Hobson’s choice
at what time of the day does a group acquire a new member?
accrued liabilities on entry that are recognised later for tax.
Geoff is a Tax Counsel with PricewaterhouseCoopers. He has been involved in the development of the consolidation provisions as a member of Treasury's Consolidation Joint Design Team. He is a Taxation Institute representative on the Consolidation Subcommittee of the National Tax Liaison Group. Current at 11 April 2007
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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