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Case studies and suggested solutions: Tax consolidations for SME’s - What have we learned paper?


This paper focuses on a number of critical issues that we as taxation professionals are facing when advising SME's on whether or not to consolidate:

  • should we have formed a group already? There are potentially a number of missed opportunities from not doing so
  • tax risks to be considered in structuring a tax consolidated group
  • tax consolidation as a strategy for preparing a group for a management buy-in or preparation to a sale of part of the operations
  • buying and selling assets vs shares from a consolidated group
  • non-tax issues in moving assets around a tax consolidated group for example how effective is asset protection in this situation if a member of the group is subsequently placed in liquidation?
  • CGT events and other tax consequences arising from the exit of companies. Quite often some slightly unexpected results can occur
  • giving an ‘equity' type interest in a company in the group without breaking the consolidated group.

Author profile

Timothy Sandow CTA
Tim is an experienced tax professional with 25 years in the ‘Big 4’, he provides income tax related advice to a variety of private and large public companies as well as multi-nationals. In particular, Tim has advised many companies on mergers & acquisitions, tax governance, corporate tax, international tax, and employment tax issues, always maintaining a focus on practical commercial advice. One of Tim’s key skills is understanding complex tax issues and communicating these in a practical way enabling CFO’s, Boards and Business Owners to focus on the key opportunities and risks when making business decisions. Tim is currently the SA representative on National Council of The Tax Institute. - Current at 17 July 2020
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This was presented at South Australian Tax Intensive .

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Tax consolidations for SME’s - What have we learned?

Author(s):  Tim SANDOW

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