The practical issues arising for vendors and purchasers when selling and buying entities in a consolidated income tax environment are considered in this paper, including:
- implications of the single entity rule on funding and acquisition costs
- implications for sale contracts
- CGT on deconsolidation including traps with CGT Event L5
- anomalies with loss transfers on restructures and partial sell downs.
Kirsten is a Partner in the International Tax and Transactions Services group at PricewaterhouseCoopers. Kirsten has over fourteen years experience in providing structuring and due diligence advice on large M&A transactions, particularly for property and infrastructure clients.
Paul is a Partner in the Corporate Tax group of PwC in Melbourne and has over 25 years experience advising local and international clients on income tax issues. Paul has significant experience in relation to tax due diligence, acquisition structuring, capital raisings and IPOs. The focus of his work is presently issues surrounding consolidation, imputation, capital returns, the taxation of trusts and international tax. More recently, Paul has been leading and driving PwC's Tax Reform project, aimed at building momentum within the community around the need for comprehensive tax reform in Australia. Most notably, through the development of two formal consultative groups of CEOs, CFOs, chairpersons, and union and charity representatives to help drive dialogue and debate on the issue, culminated in PwC's Protecting our Prosperity series of publications. Paul also drives momentum in the tax reform space through targeted events and engagements across Australia. Current at 14 July 2016
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Rob has worked with PwC for over 12 years specialising in international tax and Mergers and Acquisitions. Rob is PwC's Head of Mining for the Tax Practice in WA and provides services to a number of mining and mining services clients. Rob provides advice to a number of multinational and ASX listed clients on M&A transactions, cross-border funding and repatriation, tax consolidation and corporate reorganisations.