Issues on exiting from a consolidated group presentation

Published on 22 Feb 05 by VICTORIAN DIVISION, THE TAX INSTITUTE

Issues covered in this presentation include:

• when does an entity exit? - special issues on liquidation and for MEC groups
• a CGT event L5 if liabilities exceed the tax cost of assets - a problem with insolvent subsidiaries
• assets which may not have a cost base on exit
• what is the tax value of intra-group assets and liabilities when an entity leaves a group?
• issues with merged and split assets and goodwill
• issues with liabilities and the impact of IFRS, the interaction between s711-45(3) and (5)
• if Division 149 applies after the formation of a group, what is its effect on the disposal of a subsidiary member with a pre-CGT factor?
• when is the gain or loss of the head company on the disposal of membership interests
• in subsidiary member on revenue or capital account.

This was also presented by Paul Abbey at the Tax Consolidation seminar held in Sydney on 22 February 2005.

Author profile

David Romans

David works for PricewaterhouseCoopers. - Current at 05 July 2009

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