Published on 28 Nov 08
by TASMANIAN DIVISION, THE TAX INSTITUTE
While the tax consolidation regime for corporate groups has now been operating for over 6 years, a large number of privately owned groups and their advisors are not totally familiar with how the regime operates in practice.
This paper provides practical direction as to the tax implications of a group electing to consolidate, and how to undertake the associated ‘entry' and ‘exit' calculations.
This paper covers:
determining what entities are eligible to join a consolidated group
determining how to reset the tax value of assets of an entity that joins a consolidated group
reviewing the implications of consolidations on tax losses
the implications in respect of pre-CGT intra-group shareholdings and underlying assets
addressing the implications when an entity leaves a consolidated group, and
key due diligence points relating to the acquisition of companies
Narelle McBride CTA
Narelle is a Director in the Melbourne office of Greenwoods & Freehills. Narelle has extensive experience in advising on corporate tax matters such as corporate acquisitions and disposals, the tax consolidation regime more generally, and foreign investments in the resources and other industries. Narelle has also been involved in tax consolidation consultative forums and has assisted many clients in their dealings with the ATO on various corporate tax matters including tax consolidations, financial arrangements and foreign income. Current at 02 June 2015
Ken is a Special Counsel in the Melbourne office of Greenwoods & Herbert Smith Freehills. He has been closely involved for many years in advising Australian and foreign-owned listed companies on M&A transactions and has been extensively involved with both clients and tax professional bodies in relation to all aspects of the tax consolidation regime. Ken is a past President of The Tax Institute. Current at 23 August 2016
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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