Ten years into the consolidation regime, the tax cost setting rules have changed with retrospective effect. There are also changes to the TOFA stages 3 and 4 interaction rules. This paper concentrates on issues of vital importance to corporate taxpayers and their advisers, and covers:
- practical issues in dealing with retrospective amendments
- what is left to claim: contracts, intangibles and consumables
- the business acquisition model and future acquisitions
- the TOFA–consolidation interfact
- the impacts for SMEs
- the Board of Taxation’s post-implementation review.