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Q&A: Tax consolidation, Div 7A and the Small Business Concessions


Ever since tax consolidation came into effect on 1 July 2002, there has been considerable difficulty in applying consolidation principles such as the entry history rule and the single entity rule to existing tax laws. In many cases, the laws were incompatible with each other and led to outcomes that were clearly contrary to what Parliament originally intended. This has lead to a number of Australian Taxation Office rulings, determinations and interpretive decisions. It has also led to a myriad of amendments to the consolidation legislation.

Author profiles

Andrew O'Bryan CTA
Photo of author, Andrew O'BRYAN Andrew is a senior Tax Partner at Hall & Wilcox Lawyers. He has nearly 35 years experience giving expert tax advice to private business and wealthy family groups. He has particular expertise in the tax aspects of succession planning and in managing complex disputes with the ATO. - Current at 04 January 2018
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Jerome Tse CTA
Photo of author, Jerome TSE Jerome is a Partner at King & Wood Mallesons, specialising in taxation disputes and litigation. Jerome advises corporate taxpayers on all aspects of Australian tax disputes from the audit and independent review stage through to High Court litigation. He also guides clients through alternative dispute resolution processes, advance pricing agreements and mutual agreement procedures. - Current at 25 October 2017
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