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Taxation of Mergers and Acquisitionsis a capstone subject in the Master of Taxation, designed for tax professionals and government officials who wish to complete or update their education in corporate tax law and practice. Coordinated and taught by some of Australia’s leading tax advisers, it is focused around a series of topical issues. Using a detailed analysis of these issues, it provides students with in-depth, commercially relevant knowledge of the tax rules for mergers and acquisitions of public and private companies and consolidated corporate groups.
Topics include the application of rollovers that benefit shareholders and companies engaged in takeovers and mergers, especially involving consolidated groups, as well as applicable tax integrity rules and recent and ongoing tax reform.
Principal topics include:
- Corporate capital gains tax rollovers for mergers, acquisitions and disposals, including Divisions 124, 125 and 126 of the Income Tax Assessment Act 1997 (Cth), in particular scrip for scrip, demerger and various corporate restructure rollovers
- The interaction of tax rules relating to mergers, acquisitions and restructures with key elements of the tax rules for consolidated corporate groups in Part 3-90 of the Income Tax Assessment Act 1997 (Cth) including rules for tax cost setting on entry and exit, foreign-owned multiple entry consolidated groups, tax-sharing and payment, due diligence and corporate risk
- The interaction of tax rules relating to mergers, acquisitions and disposal with the imputation system and corporate financing tax rules.
Intended learning outcomes
A student who has successfully completed this subject will:
- Understand the detailed legal rules applicable in the taxation of corporate mergers and acquisitions, particularly as they apply to consolidated groups
- Have a good knowledge of legal and tax structures used for corporate mergers and acquisitions in practice
- Be aware of current problems and reforms in taxation of corporate mergers and acquisitions.
Last updated: 18 December 2020