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This advanced corporate tax subject provides an in-depth analysis of the tax rules for Australia‘s largest public and private consolidated corporate groups, and the rules for use of losses by companies and corporate groups. It includes detailed discussion of the latest reforms in these highly technical areas of corporate tax practice, in light of tax policy applicable to companies and consolidated groups operating in Australia today. This subject is co-taught by experienced lecturers who combine academic and practitioner experience to deliver this advanced and commercially essential subject.
Principal topics include:
- The rules for membership and formation of a consolidated group in Part 3-90 of the Income Tax Assessment Act 1997 (Cth)
- Operation of a consolidated group through normal trading operations, including the single entity rule, treatment of assets and liabilities, tax payment obligations, tax-sharing agreements and the company shareholder imputation system for consolidated groups
- Tax cost setting on joining and leaving of subsidiary members of a consolidated group, including group-to-group transactions
- Tax rules for multiple entry groups owned by foreign investors in Australia
- The interaction of consolidated group tax rules with other tax rules
- Tax rules for losses in companies and consolidated groups, including loss integrity rules, in Divisions 165 and 166 of the Income Tax Assessment Act 1997 (Cth).
Intended learning outcomes
A student who has successfully completed this subject will:
- Have an advanced and integrated understanding of the tax rules and practical problems involved in the taxation of consolidated corporate groups
- Be able to critically examine, analyse, interpret and assess those rules
- Be an engaged participant in debate regarding the policy and issues underlying these rules
- Have a sophisticated appreciation of the factors and processes driving reform of the tax framework
- Have an advanced understanding of the tax rules applicable to company losses
- Have a detailed understanding of the most recent tax reforms in these areas, in light of the applicable policy and existing law
- Have the cognitive and technical skills to generate critical and creative ideas relating to taxation of corporate groups and corporate tax losses, and to critically evaluate them
- Have the cognitive and technical skills to independently examine, research and analyse taxation of consolidated corporate groups and corporate tax losses
- Have the communication skills to clearly articulate and convey complex information regarding those rules to relevant specialist and non-specialist audiences
- Be able demonstrate autonomy, expert judgment and responsibility as a practitioner and learner in the field of consolidated corporate groups and corporate tax losses.
Last updated: 11 February 2021