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Recouping tax losses under Division 166 paper

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Published on 27 May 09 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • the role of Division 166
  • the companies to whom Division 166 applies
  • how Division 166 modifies the basic continuity of ownership test
  • corporate change
  • the tracing concessions
  • the stakeholder thresholds of the concessional tracing rules
  • the no detriment rule: section 166-275
  • interposition of a new entity between notional shareholders.

Author profiles

Martin Fry FTI
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. Martin represented the taxpayer in Shell Energy v Commissioner of Taxation before the Federal Court, Full Federal Court and High Court. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. Martin has extensive experience in contentious matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne. - Current at 28 September 2022
Click here to expand/collapse more articles by Martin FRY.
Jeannelle Menezes
Jeanelle works for Allens Arthur Robinson. - Current at 05 May 2009
Click here to expand/collapse more articles by Jeanelle MENEZES.

 

This was presented at Everything There is to Know About Company Losses and Tax .

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Individual sessions

The continuity of ownership test under Division 165

Author(s):  Andrew VAN DINTER,  Brian LANE

Materials from this session:

The same business test under Division 165

Author(s):  Andrew WOOLLARD,  Brian LANE

Materials from this session:

Losses and tax - The loss integrity measures

Author(s):  Enzo COIA

Materials from this session:

Recouping tax losses under Division 166

Author(s):  Martin FRY,  Jeanelle MENEZES

Materials from this session:

Losses and consolidation - Entries and exits

Author(s):  Duncan R C BAXTER

Materials from this session:

Further details about this event:

 

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