Published on 10 Oct 13
by VICTORIAN DIVISION, THE TAX INSTITUTE
Given the on-going uncertainty with respect to the taxation of trusts and increasing compliance costs of operating trust structures traditionally utilised by many family “groups”, there is renewed focus on tax consolidation for SME clients. This paper addresses why you would consider adopting the complex tax consolidation rules for certain SME clients and how to steer your way through these complexities.
a brief introduction to tax consolidation and the current state of play
migrating current structures (eg rollovers of trusts or partnerships to companies, and the interplay between the inherited history and single entity rules)
forming a consolidated group – the value proposition (advantages and disadvantages of the ACA calculation, including the loss of pre-CGT status and step-up in cost base of depreciable assets)
accounting for tax consolidated groups – anintroduction to UIG 1052
distributions to investors (treatment of dividends,loans etc)
introducing new funding and investors
leaving a consolidated group (eg CGT event L5and clear exit)
Neil Lamb ATI
Neil is a Partner at KPMG in Perth who specialises in mergers and acquisitions. He has advised a range of clients in the large corporate and SME market place in relation to both acquisitions, demergers, divestments and refinancing across a diverse range of businesses. Current at 29 May 2015
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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