Published on 01 Nov 07
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
The focus of this paper is on recent corporate tax loss related developments, including the application of the same business test within consolidated groups and recent court decisions on tax loss utilisation:
- same business test ruling (TR 2007/2)
- FCT v R&D Holdings Pty Ltd
- impact of removal of $100m SBT cap
- Keycorp Ltd v FCT
- Coal Developments v FCT
- impact of ROSA amendments
- other recent developments.
Andrew is a Tax Partner with Ernst & Young, working in corporate and international tax. Andrew has worked extensively with corporate groups with significant tax losses. This work has included ATO tax loss audit activity, continuity of ownership testing, same business testing, loss integrity impacts, as well as the impacts of the tax consolidation regime on tax losses when forming a consolidated group or as part of post consolidation M&A activity.
Current at 26 September 2007
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