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Tax consolidation update: Still grappling with these rules?


Reform of the tax consolidation regime has stagnated over the last few years. A broad review was to be undertaken in 2015, but little was done apart from preliminary discussions and compilation of lists. The most recently announced changes of significance, relating to deductible liabilities, securitised assets and anti-churning where companies are transferred from non-residents, still await amending legislation after more than three years. The 2016-17 federal Budget added further refinements to those previously announced proposals.

This article examines the current state of the announced changes, and what they should look like when eventually introduced. The article
also looks back at the long list of outstanding announcements, identified issues and areas for improvement of the tax consolidation rules. The hope is expressed that an incoming government will re-prioritise the broad tax consolidation review, in line with clear policy objectives.

Author profile

Wayne Plummer ATI
Photo of author, Wayne PLUMMER Wayne Plummer is a Tax Partner at PwC with over 30 years of corporate tax experience. He advises a range of multinational companies in relation to their Australian tax affairs. Wayne specialises in the tax consolidation rules, capital management and M&A. - Current at 19 June 2018
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