Published on 18 Jul 03
by VICTORIAN DIVISION, THE TAX INSTITUTE
This seminar paper covers the following issues:
- transferring losses into consolidated groups
- curiosities in value and loss donation
- capital injection and non-arms length rule
- applicability of SBT to a consolidated group
- transfer of a current year loss in a non-membership period to head company
- operation of 701-30(3A) re: ownership changes at the joining time
- establishing the available fraction
- modified rules for MEC groups
- transition rules - COT losses.
Garry is a Corporate Tax Partner with Deloitte Touche Tohmatsu and is a member of the firm's national tax consolidation team. Garry is currently providing extensive tax consolidation structuring and planning advice to a number of large domestic and multinational corporate groups.
- Current at
18 July 2005
Richard is a Corporate Tax Partner with Deloitte Touche Tohmatsu. He specialises in advising major corporates on the tax implications of major transactions such as mergers and acquisitions, divestments, restructures and IPOs. Richard also has experience in advising corporates on implementing both A-IFRS and tax consolidation. Richard is a member of the NTLG IFRS subcommittee and the ICAA IFRS subcommittee and has been heavily involved in the consultation with respect to the development of the share capital tainting provisions.
- Current at
11 September 2006