Published on 13 Dec 05
by VICTORIAN DIVISION, THE TAX INSTITUTE
This presentation covers the following topics:
- evidence of the intended scope of the demerger relief
- the need for dividend relief (currently the subject of litigation)
- the 'demerger specific' aspect of s 45B
- the 'dividend substitution' aspect of s 45B for demergers
- examples of situations where s 45B will, or will not apply
- in a word...is your proposed demerger...'genuine'?
Richard Shaddick FTIA is a Director of Greenwoods & Freehills in Melbourne. He has extensive experience in international taxation with his primary area of interest being the taxation of controlled foreign companies. Richard is a member of the Public Rulings Panel of the Australian Taxation Office. He is a former State & National Councillor of the Taxation Institute, and a former Australian President of the International Fiscal Association. He represented the Taxation Institute on the Tax Treaties Advisory Panel from 1997-2006. He is an occasional member of the GAAR Panel.
- Current at
11 March 2009