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Income equalisation within a corporate group presentation

Published on 15 Jun 04 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation looks at the scope for 'self-help solutions' to the effective repeal of the loss grouping system. Prior to the enactment of these rules, tax advisers well understood some of the options for income equalisation within a corporate group - how did they do it? How many of those strategies are still available in the face of:
- arm's length pricing rules - for income derived from associates, for expenses incurred to associates, for measuring the cost base of assets and the capital proceeds of sales
- the impact of the new debt-equity rules on options involving corporate financing opportunities
- the 'stop loss' rules
- the surviving rollover rules and where they can help
- and how does Part IVA fit into all of this?

Author profile:

Peter Cowdroy FTI-Life
Peter is a Partner at Nexia Court & Co. Throughout his career, Peter has provided advice on a wide range of taxation areas, including taxation of revenue and capital gains, fringe benefits tax and GST and the practical aspects of business, such as tax planning and structuring, remuneration planning and employee incentives. In addition, Peter advises extensively on international tax issues and has been a member of the international tax committee of two international accounting networks. Current at 14 May 2004 Click here to expand/collapse more articles by Peter COWDROY.
 

This was presented at Transacting in a Non-Consolidated Group.

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