Published on 01 May 09
by NATIONAL DIVISION, THE TAX INSTITUTE
This paper covers:
background - what was at stake and what was the concern?
what the recent amendments seek to achieve
the start date for the amendments
the threshold test - "restructure"
the impact of the amendments on cost base
the replacement entity's choice to deny roll-over relief
the "stick" option for the target's assets
a worked example of the cost base outcomes in a tax consolidation context
scrip-for-scrip acquisitions - the new tax landscape
a restructure which meets the requirements of Subdivision 124-G
a restructure using CGT rollover under Subdivision 124-M involving a non-widely held target and acquiring company
a restructure using CGT rollover under Subdivision 124-M involving a widely held target or acquiring company
non-restructure using CGT rollover under Subdivision 124-M.
Richard Hendriks CTA
Richard has been a Director of Greenwoods & Freehills since 1998. Richard advises on a wide range of corporate tax matters. He has extensive experience in advising listed companies and stapled groups on mergers and acquisitions, demergers, company restructures and capital management transactions. Richard also advises listed groups on employee share and rights plans. Current at 06 February 2014
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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