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 is a Tax Partner with EY in Sydney. He advises a number of large private company and family groups on 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 subcommittees. In terms of technical development, Paul has presented at The Tax Institute and other professional institutes’ seminars on a wide range of tax topics.
- Current at
12 April 2017