Tax consolidation is entered into by way of an irrevocable election. Many SME corporate groups have delayed the consolidation decision or have chosen not to consolidate.
This paper uses a case study approach to analyse the consequences of not consolidating and issues arising from groups operating outside the consolidation environment, including:
- recap on what was lost including no access to group losses and rollover relief for CGT/UCA assets and intra-group dividend issues
- income equalisation strategies using passive and active income
- the transfer of assets including trading stock, loans, GCT and UCA assets
- the anti-avoidance rules including value shifting considerations and Part IVA
- the impact on cash flows, stamp duty and GST.