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.
Current at 15 June 2011
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