A common outcome of restructuring a business is the implementation of a corporate group involving at least the holding company and a wholly owned operating subsidiary. To fully access the benefits of the corporate group structure often requires the implementation of a tax consolidated group and a GST group.
This presentation examines the critical issues associated with forming a tax consolidated and GST group, including:
- impact of the different CGT rollovers on the consolidations formation calculations
- impact of not using CGT rollovers and relying on tax concessions such as the CGT small business concessions for the restructure
- tax detriment that can result from the formation calculations including those from internally generated goodwill
- opportunities to “uplift” the asset’s tax values
- alternative restructure approaches to minimise the consolidations’ tax detriment
- implications of the Part IVA rewrite.