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TOFA and tax consolidation presentation


This presentation covers the interaction of TOFA with the tax consolidation regime, including:

  • joining and leaving a tax consolidated group
  • elections and balancing adjustments
  • tax cost setting rules for Division 230 financial assets and financial liabilities
  • the ATO perspective
  • outstanding issues.

Author profiles:

Mark is a Partner in KPMG’s Corporate Tax Division and Legal Practitioner Director of KPMG Tax Lawyers Pty Limited. Mark specialises in taxation of capital raisings and mergers & acquisitions. Mark joined KPMG after working for 15 years with another Big Four accounting firm and four years as a solicitor. Mark has written numerous technical papers in the areas of corporate restructures and the taxation of debt and equity. He was educated at St John’s College, Cambridge and has a honours degree in law from Monash University, Victoria.
Current at 9 February 2009 Current at 14 May 2009 Click here to expand/collapse more articles by Mark POOLE.
Julian Humphrey FTIA has 12 years experience with the KPMG Banking & Finance Tax Practice. He works primarily with international banks and financial services companies operating in Australia providing corporate income tax services. Julian’s areas of expertise includes the taxation of banks and bank branches, the taxation of financial arrangements and retail financial products as well as Australia’s offshore banking regime. He is a regular participant in consultation with Government on Australia’s tax reform proposals affecting Australian financial institutions.
Current at 9 February 2009 Current at 18 May 2009 Click here to expand/collapse more articles by Julian HUMPHREY.


This was presented at 4th National Consolidation Symposium .

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

Individual sessions

ATO perspective on consolidation - Unravelling the mysteries of the single entity rule

Author(s):  Des MALONEY,  Peter WALMSLEY

Materials from this session:

Consolidation: Legislative changes (Part B)

Author(s):  Peter MURRAY

Materials from this session:

Consolidation and mining assets – Some selected acquisition issues checklist

Author(s):  Cameron RIDER

Materials from this session:

Tax consolidation – Financial services

Author(s):  Tony STOLAREK

Materials from this session:

Further details about this event:


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