Published on 01 Jun 09
by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE
The tax consolidation exit rules, which apply when a subsidiary leaves a consolidated group, could be regarded as the “poor cousin” in consolidation. Historically they have received less attention than the provisions dealing with forming or entering a group. This paper considers the application of the exit tax calculations and highlights some anomalies that can catch the unwary. It also looks at alternatives available to a vendor to selling shares in a subsidiary.
Hayden is a partner at McCullough Robertson, acting for corporate groups, both listed and privately held, and high net worth individuals on a range of structuring and taxation issues. He has advised on complex tax audits and disputes with the Australian Taxation Office (ATO) on issues such as Division 7A and private company loans, tax consolidation and cross-border restructures.
- Current at
16 December 2015