Published on 09 Sep 04
by VICTORIAN DIVISION, THE TAX INSTITUTE
The rules for use of tax losses have once again been subjected to considerable change. This paper analyses the recent reforms as they affect corporate groups. Case studies are used to analyse:
- the new continuity of ownership test
- impact of the abolition of the same business test on corporate acquisitions
- the same business test applied to consolidated groups
- tricks in applying pre consolidation losses to post consolidation gains
- the loss denial rules.
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. In recent years, Martin has focused on contentious transfer pricing matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne.
- Current at
12 May 2021
Brad, a Senior Associate with Allens Arthur Robinson, practices in international and corporate taxation. He has experience in a wide range of income tax matters including sales, acquisitions and restructures, financing arrangements, and advising companies on the impact of tax consolidation in M&A transactions.
Current at 23 July 2004