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Leaving a consolidated group – the sting in the tail

Taxation in Australia | 1 Jun 09
 
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Published on 01 Jun 09 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

The tax consolidation exit rules, which apply when a subsidiary leaves a consolidated group, could be regarded as the “poor cousin” in consolidation. Historically they have received less attention than the provisions dealing with forming or entering a group. This paper considers the application of the exit tax calculations and highlights some anomalies that can catch the unwary. It also looks at alternatives available to a vendor to selling shares in a subsidiary.

Author profile

Hayden Bentley
Hayden Bentley is Chief Tax Counsel at Macpherson Kelley, acting for corporate groups, and high net worth individuals on a range of structuring and taxation issues. He has advised on the tax consolidation rules since their introduction over 20 years ago, and has a particular focus on advising privately owned groups on restructuring to enter the tax consolidation regime, and managing the potential adverse tax consequences of doing so. - Current at 10 January 2024
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