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5th Consolidation Symposium

Published on 14 Oct 2010 | Took place at Sofitel Melbourne on Collins, Melbourne, National

This year’s Symposium had as its central feature the long awaited introduction of the 2005 press release and the introduction of the new concept of “rights to future income”.

This event had a number of sessions that used practical examples to examine the complexities of these new concepts, including the unique additional two year amendment period which will expire in June 2012. Examined in greater detail was the interaction of tax consolidation in a number of specialist areas, including mining, M&A, TOFA and SMEs.

There was also a focus on the future, with the Australian Taxation Office providing insight into their compliance approach to tax consolidation, with particular focus on the ATO experience on “rights to future income deductions”. In our final session a Board of Taxation member considered consolidation beyond the immediate and shared his thoughts on the shape of the tax consolidation regime in the future.

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

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Individual sessions

Tax consolidation law changes - Counsel and practitioner perspectives

Author(s):  Colin Jones This paper covers:

  • policy intent
  • need for amendment
  • observations on the modified Subsection 701-55(6).
Materials from this session:

Tax consolidation law changes - Counsel and practitioner perspectives

Author(s):  Michael FLYNN This paper covers:

  • definition of rights to future income
  • interpretation of tax cost deeming provision, Section 701-55(6).
Materials from this session:

Tax consolidation law changes - Counsel and practitioner perspectives

Author(s):  Peter MURRAY This paper covers:

  • TLAA 1 amendments
  • use of tax cost setting amount (TCSA).
Materials from this session:

Rights to income and other new deductions

Author(s):  Andrew WOOLLARD,  Wayne PLUMMER,  Nigel Smythe This paper covers:

  • background - company versus asset acquisitions
  • rights to income
  • revenue assets/circulating capital
  • other non-contractual customer intangibles
  • the new "rights to income" - through a valuer's lens.
Materials from this session:

Specialist industries - Resource groups

Author(s):  Andrew VAN DINTER This paper covers:

  • Subsection 701-55(6) and related amendments and their application to unique resource company assets
  • application of right to future income (RFI) rules to resource groups.
Materials from this session:

Merger & acquisition transactions - Accounting issues

Author(s):  Kris PEACH This paper covers:

  • divestments/demergers
  • acquisitions
  • tax consolidation legislation amendments.
Materials from this session:

Merger & acquisitions transactions

Author(s):  Richard HENDRIKS This paper covers:

  • interaction of the demerger rules with the tax consolidation regime
  • no demerger relief for CGT event L5
  • head company as a "demerging entity"?
  • cost setting anomoly
  • CGT straddle contracts - intra-group dealings
  • straddle contract between group members
  • straddle contract over an intra-group interest.
Materials from this session:

Financial services: TOFA and consolidation

Author(s):  Mark GOLDSMITH,  Mark POOLE This paper covers:

  • treatment of stub period of joining entity
  • treatment of head company on joining the tax consolidated group
  • exit rules - head company
  • exit rules - leaving entity.
Materials from this session:

SMEs and tax consolidation

Author(s):  Alexis KOKKINOS This paper covers:

  • dealing with pre-CGT interests
  • positions by the Board of Taxation
  • concessional measures suggested by the Board.
Materials from this session:

International tax including MECs

Author(s):  Vivian CHANG,  Peter COLLINS This paper covers:

  • why are MECS special?
  • conversions between consolidated groups and MEC groups
  • MEC reorganisations
  • traps with losses for MEC groups
  • other topical MEC group issues.
Materials from this session:

Compliance - ATO perspective

Author(s):  Scott Burrows This presentation covers:

  • compliance program - 2010-11
  • unintended or inappropriate outcomes
  • foreign partnerships.
Materials from this session:

The future of consolidation

Author(s):  Ken SPENCE

This paper covers:

  • policy framework for the consolidation regime
  • operation of the single entity rule
  • interaction between the consolidation regime and other parts of the income tax law
  • operation of the consolidation regime and small business corporate groups
  • issues to be considered outside the review process.
Materials from this session:

Post implementation review of certain aspects of the consolidation regime

Author(s):  Keith JAMES This presentation covers:

  • scope of the review
  • review process
  • position paper
  • key positions.
Materials from this session: