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Mergers and acquisitions in a post-consolidation world paper

Published on 16 Feb 06 by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA

This paper provides commentary on the following topical issues affecting M & A transactions involving tax consolidated groups:

  • the effect of an SBT ceiling on the ability of a bidder to acquire the carry-forward losses of a target entity
  • the effect of an SBT ceiling on the ability of a bidder to claim bad debt deductions for debts "inherited" from a target entity
  • the characterisation of the sale of membership interests in subsidiary members, particulary in having regard to the quantum of capital losses currently existing in the tax system
  • whether a consolidated group will be denied a loss on the sale of a loss-making subsidiary member , if the subsidiary member is sold to another consolidated group

 

Author profile

Martin Fry FTI
Martin has been a Partner in the Allens Tax Group for 20 years and in that time has been extensively involved in advising resource companies, infrastructure projects, banks and IP intensive businesses. In recent years he has focused on contentious cross border issues, both from a litigation perspective and in alternative dispute resolution. - Current at 30 November 2020
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This was presented at 2006 Financial Services Taxation Conference: From every angle .

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Interpreting and applying the tax regime in practice - a legal perspective

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