It's been approximately 10 years since the introduction of the tax consolidation rules. Unique compared to other consolidation regimes globally, a combination of legislative tinkering, major reform and the interaction of the rules with other parts of the Income Tax Assessment Act mean the rules can still represent a mine field for the unwary. Even for the well informed, the rules can produce unexpected outcomes.
In this presentation designed for those familiar with the tax consolidation rules, Paul Abbey (Partner, PwC) and Rob Bentley (Partner, PwC) examine some of the pitfalls and opportunities the provisions present. The interaction of the rules with other parts of the Act such as TOFA and thin capitalisation will be discussed as will the interaction of the tax consolidation rules in the context of Mergers & Acquisitions and capital market
transactions.
This presentation is designed to provide tax specialists within Corporates and professional advisors alike with an update of current planning considerations that might be available when acquisitions are undertaken and matters to consider during due diligence.