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Tax consolidation – Practical issues in the current law paper

Published on 09 Oct 14 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • uncertainty in the current law
  • uncertainty in proposed law – deductible liabilities 
  • some other practical issues to note.

Author profiles

Narelle McBride CTA
Narelle McBride, CTA, is a Managing Director at PwC with over 25 years’ experience advising some of Australia’s largest corporate and privately owned enterprises, comprising varying business structures such as companies, trusts, partnerships and joint ventures. Her clients conduct business across many sectors including retail, property, primary industries and energy and resources. Narelle advises on general income tax matters as well as Australian tax issues associated with restructures, acquisitions and divestments. This extends to planning, due diligence and managing ATO interactions, reviews and disputes. She also advises on internal and external restructures involving debt financing arrangements, rehabilitation projects and closure projects. - Current at 29 January 2026
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Ryan Leslie ATI
Ryan is a Partner in the Melbourne office of Herbert Smith Freehills. Ryan has more than 10 years’ experience in advising on the income tax aspects of a broad range of corporate, international and trust tax taxation matters, with a particular focus on the infrastructure and energy sectors. Ryan specialises in advising on mergers and acquisitions, internal restructures, and disputes. - Current at 30 November 2022
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Kenneth Spence CTA-Life
Photo of author, Ken SPENCE Ken is a Special Counsel in the Melbourne office of Greenwoods & Herbert Smith Freehills. He has been closely involved for many years in advising Australian and foreign-owned listed companies on M&A transactions and has been extensively involved with both clients and tax professional bodies in relation to all aspects of the tax consolidation regime. Ken is a past President of The Tax Institute. - Current at 23 August 2016
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This was presented at 2014 National Resources Tax Conference .

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A new era in transfer pricing

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