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Exit demerger tax relief

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DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 12 Dec 02 by VICTORIAN DIVISION, THE TAX INSTITUTE

This powerpoint presentation discusses the criteria for CGT relief, nature of CGT relief, consequences for the corporate group, dividend relief for shareholders, and dividend treatment for demergers which are not 'geniune'.

Author profile

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

More by Martin FRY

Shell Energy - What does this case mean for Exploration in an Income Tax and PRRT context? paper - 10-November-2022
Commercial rationality: why does it matter and how do I prove it? paper - 25-August-2022
A new phase in transfer pricing dispute resolution in Australia paper - 09-September-2021
Baseball playbook - MLI, MAP and mandatory binding arbitration paper - 11-November-2020
What's new for tax losses? paper - 26-October-2016
Securitised lease/licence arrangements paper - 28-May-2015
Financing resource projects paper - 15-October-2014
Expanding TARP to capture goodwill and mining information - 01-October-2013
Expenditure on exploration or prospecting paper - 25-October-2010
Company losses - An old issue for a new era paper - 05-March-2010
Hybrid financial instruments: Classifying hybrid instruments under the debt/equity rules and related issues paper - 09-October-2009
Classifying hybrid instruments under the debt/equity rules and related issues paper - 09-October-2009
Corporate financing paper 19112009 - 09-October-2009
Recouping tax losses under Division 166 paper - 27-May-2009
Current issues facing corporates in interpreting the debt equity rules in a cross border context paper - 02-November-2007
Mergers and acquisitions in a post-consolidation world paper - 16-February-2006
Debt/equity: comments on recent developments, overseas experiences and Section 974-80 paper - 17-November-2005
Consolidation: focussing on the formation tax return seminar paper - 28-October-2004
Recent developments in tax losses for companies convention paper - 09-September-2004
Mergers and Acquisitions - Some Current Issues convention paper - 12-September-2003
Exit demerger tax relief - 12-December-2002
Simplified imputation - case studies - 12-September-2002
Capital management - 21-June-2002
Workshop three: capital allowances - 23-February-2001
Loss and Integrity Measures - 21-November-2000
Loss and integrity measures - 07-September-2000
Loss and integrity measures - 20-June-2000

Click here to expand/collapse more articles by Martin FRY.

This was presented at Mergers & Acquisitions: Exit (Session 3) .

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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Exit strategies

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Mergers & Acquisitions: Exit (Session 3)

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Exit demerger tax relief

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Martin Fry FTI

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