- CGT rollover relief especially Subdivision 126-B
- scrip for scrip and other CGT concessions (other than the demerger concessions)
- loss integrity measures including 'same share / same owner' rule, the unrealised loss provisions and the integrity measures aimed at loss cascading
- the preservation of tax attributes by the Group during the reorganisation
- the application of Part IVA in the context of such reorganisations.