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Andy Hirst FTIA (Greenwoods & Freehills) attended a special meeting on Wednesday 1 June 2011 of members of the TOFA Working Group to discuss the complex area of the interaction of Division 230 and the consolidation regime. The consultation meeting arose following a submission made by the Professional Bodies on how the provisions possibly operate in a situation where:

  • a consolidated group acquires an entity that has various financial arrangements prior to the commencement of TOFA; and
  • upon the commencement of the TOFA provisions, the head company of the consolidated group decides to un-grandfather its existing financial arrangements.   

If you are interested in TOFA/consolidation interactions, we can provide more information. Please contact us at Tax Policy.

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