Have the courts settled how tax consolidation is to be interpreted and applied?
Aldrin DE ZILVA
This paper examines the decisions handed down since the introduction of tax consolidation to determine how the courts have dealt with tax consolidation legislation. It also explores the themes and principles that can be taken from those decisions including in relation to the core rules.
What still remains unresolved in tax consolidation?
Whilst the BoT’s reviews and the Government’s responses outline changes to be made to the consolidation regime, there are still many outstanding issues in tax consolidation which have grown with the proposed changes made in 2012. This presentation covers some of the outstanding items and where they might end up, including:
deductions for work in progress
scope of the RTFI under prospective rules and treatment of rights to future income