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Section 45B and demergers presentation

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'?

Author profile

Richard Shaddick
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
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Section 45B and demergers

Author(s):  Richard SHADDICK

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