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Recouping tax losses under Division 166 paper

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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 27 May 09 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • the role of Division 166
  • the companies to whom Division 166 applies
  • how Division 166 modifies the basic continuity of ownership test
  • corporate change
  • the tracing concessions
  • the stakeholder thresholds of the concessional tracing rules
  • the no detriment rule: section 166-275
  • interposition of a new entity between notional shareholders.

Author profiles

Martin Fry FTI
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. In recent years, Martin has focused on contentious transfer pricing matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne. - Current at 12 May 2021
Click here to expand/collapse more articles by Martin FRY.
Jeannelle Menezes
Jeanelle works for Allens Arthur Robinson. - Current at 05 May 2009
Click here to expand/collapse more articles by Jeanelle MENEZES.

 

This was presented at Everything There is to Know About Company Losses and Tax .

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Individual sessions

The continuity of ownership test under Division 165

Author(s):  Andrew VAN DINTER,  Brian LANE

Materials from this session:

The same business test under Division 165

Author(s):  Andrew WOOLLARD,  Brian LANE

Materials from this session:

Losses and tax - The loss integrity measures

Author(s):  Enzo COIA

Materials from this session:

Recouping tax losses under Division 166

Author(s):  Martin FRY,  Jeanelle MENEZES

Materials from this session:

Losses and consolidation - Entries and exits

Author(s):  Duncan R C BAXTER

Materials from this session:

Further details about this event:

 

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