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Issues regarding SMEs and group structures paper


A common outcome of restructuring a business is the implementation of a corporate group involving at least the holding company and a wholly owned operating subsidiary. To fully access the benefits of the corporate group structure often requires the implementation of a tax consolidated group and a GST group.

This paper examines the critical issues associated with forming a tax consolidated and GST group, including:

  • impact of the different CGT rollovers on the consolidations formation calculations
  • impact of not using CGT rollovers and relying on tax concessions such as the CGT small business concessions for the restructure
  • tax detriment that can result from the formation calculations including those from internally generated goodwill
  • opportunities to “uplift” the asset’s tax values
  • alternative restructure approaches to minimise the consolidations’ tax detriment
  • implications of the Part IVA rewrite.

Author profile:

As a Partner in the Taxation Consulting group at PKF Sydney, Paul provides tax consulting, planning, compliance and advisory services to a range of public and large private companies. He has considerable experience in advising a wide range of clients and in dealing with the relevant taxation legislation as it affects them. Paul regularly presents professional development seminars for the Institute of Chartered Accountants, CPAs and National Institute of Accountants on topics such as tax reform, restructuring, business sales, employee share schemes and updates on tax cases and tax rulings.
Current at 1 July 2005 Current at 25 September 2010 Click here to expand/collapse more articles by Paul LYON.


This was presented at 20th National Tax Intensive Retreat: Expanding the Family Business .

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Workshop 1 questions and answers

Author(s):  Jo-anne HOTSTON

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Author(s):  David MARSCHKE

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Workshop 3 questions and answers

Author(s):  Michelle HARTMAN,  Kevin J MUNRO

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Intellectual property, goodwill and taxation

Author(s):  Domenic CARBONE

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