Consolidation Miscellaneous 2015

Tax consolidation changes

Source: The Tax Specialist Journal Article

Published Date: 1 Aug 2015


The tax consolidation regime has recently undergone substantial amendment, and there are more amendments to come. This article considers the recent round of amendments, namely, changes relating to the tax cost of rights to future income and the residual tax cost-setting rule, and the interaction of the taxation of financial arrangement rules with tax consolidation. The article also discusses forthcoming changes embodied in the recommendations of the Board of Taxation contained in the Restoring Integrity to the Consolidation Regime exposure draft legislation released by Treasury on 28 April 2015. The authors conclude that, following the recent amendments, there are several issues on which different interpretations are open to taxpayers and the ATO alike.The impending introduction of further legislative changes will also keep all in the industry busy, as will the on going reviews into a number of recommendations of the Board of Taxation, and the MEC group rules.

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Consolidation Miscellaneous 2015

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