Published on 10 Sep 04
by VICTORIAN DIVISION, THE TAX INSTITUTE
Tax consolidation is entered into by way of an irrevocable election. Many SME corporate groups have delayed the
consolidation decision or have chosen not to consolidate.
This paper uses a case study approach to analyse the consequences of not consolidating and issues arising from
groups operating outside the consolidation environment, including:
- recap on what was lost including no access to group losses and rollover relief for CGT/UCA assets and intra-group dividend issues
- income equalisation strategies using passive and active income
- the transfer of assets including trading stock, loans, GCT and UCA assets
- the anti-avoidance rules including value shifting considerations and Part IVA
- the impact on cash flows, stamp duty and GST.
Craig McCormick CTA
Craig is an experienced accountant and tax consulting professional specialising in working with large international businesses, listed groups
and large privately held businesses. He leads Grant Thornton's national research and development tax specialist team. In this role he works
with clients involved in innovation and assists in securing R&D tax concessions, other innovation related government incentives and
management of IP. Current at 14 September 2010
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