Your shopping cart is empty

Recouping tax losses under Division 166 paper


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 has been a Partner in the Allens Tax Group for over fifteen years, and has focused on resource companies, banks and infrastructure projects. He has extensive experience advising on the tax aspects of capital management transactions for ASX-listed companies, most recently in relation to Rio Tinto's 2015 off-market tender share buyback and on-market share buyback. He has also advised APRA-regulated banks on the tax aspects of hybrid equity and subordinated debt instruments. He advises consortia and financiers on the tax aspects of project finance for major infrastructure projects including M2, M5 and M7 motorways, among others. He is a Senior Fellow of the Law Faculty of the University of Melbourne. - Current at 12 February 2016
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 .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Further details about this event:


Copyright Statement
click to expand/collapse