Capital structuring for corporate groups presentation

Published on 07 Oct 05 by VICTORIAN DIVISION, THE TAX INSTITUTE

This presentation examines some of the lessons from recent capital restructuring (including demergers) for corporate groups. It seeks to identify some of the pitfalls that can arise for entities seeking to undertake a capital restructure and some of the criteria for a successful capital restructure. Specifically discussed are:

• the role of Subdivision 204-D and s177EA in capital management initiatives
• the application of s45B in non-demerger capital management initiatives
• the application of s45B to demergers including the draft practice statement
• related CGT consequences.

Author profile

Gordon Thring CTA

Gordon is a Partner in the Corporate Tax practice of Deloitte. He has over 20 years experience in mining and energy, financial services and property sectors. He was extensively involved in the consultation arrangements regarding the introduction of Division 125 and the amendments to s45B to accommodate demerger relief. - Current at 19 March 2009

More by Gordon THRING

• Split central management and control and dual residency - 01-July-2020
• In Search of the True Demerger: Boundary Issues with Division 125 seminar paper - 22-August-2003
• Some Issues with Demerger Relief - 01-October-2002
• Tax relief for demergers - 12-September-2002
• Demergers and corporate reconstructions - 29-August-2002
• Workshop two: consolidations - losses - 23-February-2001
• TR 97/D18: Steele's case - 01-February-1998

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