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Losses update paper


The ability of companies to preserve and utilise carry forward tax losses continues to present challenges both for taxpayers and Government Revenue.

This paper covers:

  • current status of proposed loss carry back rules and review of loss rules recommended by Business Tax Working Group report on the tax treatment of losses
  • challenges faced by taxpayers in satisfying the “continuity of ownership” and “same business” tests
  • losses in the consolidation context, including transfers of losses to the head company of a consolidated group and available fraction calculations
  • current ATO compliance activity around loss claims.

Author profiles

Kamlee Coorey CTA
Kamlee is a Tax Partner at Deloitte with over 25 years’ experience in providing commercial tax advice to Australian subsidiaries of multinationals, listed Australian corporations and large family owned organisations. She is known for distilling the application of complex legislation into an easy to understand form to help her clients address intricate tax matters. Kamlee has extensive experience in all areas of corporate taxation including structuring, acquisitions and divestments, financing and cash repatriation strategies, tax consolidations and loss recoupment testing. - Current at 15 March 2021
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Andrew Martin CTA
Andrew is a Manager at Deloitte's. - Current at 14 December 2012
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This was presented at 2012 Corporate Tax Masterclass .

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BTWG and Australia in the Asian century

Author(s):  Grant WARDELL-JOHNSON

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