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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:

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 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

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Author(s):  Michelle HARTMAN,  Kevin J MUNRO

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Intellectual property, goodwill and taxation

Author(s):  Domenic CARBONE

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