Published on 08 Nov 12
by NATIONAL DIVISION, THE TAX INSTITUTE
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.
Paul Lyon ATI
Paul is a Tax Partner with BDO in Sydney. His main practice
area is in corporate and international tax and he advises a number
of private and public companies with their tax affairs. Paul has
been part of an expert panel providing assistance to the Board of
Taxation and has sat on a number of ATO sub-committees. In terms
of technical development, Paul has presented at Tax Institute and
other professional institute seminars on a wide range of tax topics. Current at 16 October 2014
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