The payroll tax grouping provisions represent anti-avoidance mechanisms by treating different legal structures as if they were one taxpayer. With multiple points of entry into the grouping provisions, taxpayers are tasked with considering each provision in relation to their unique and often dynamic structures.
This session examined the application of the grouping provisions to particular business structures, particularly rarer structures where payroll tax may not be a principal consideration upon creation or consolidation. In this session, we will focus on practical considerations around grouping, and implications of both Tribunal and Court decisions.