The focus of this retreat was on corporate reorganisation issues. It commenced with an examination of Part IVA and CGT reduction arrangements affecting corporate restructuring issues, and then proceeded to undertake a detailed technical review of several practical implications of the new general value shifting rules, the demerger rules, accessing stamp duty relief and the CGT and loss preservation rules in the context of reorganisations.
The corporate reorganisation area was chosen as a retreat focus due to the ever-increasing prominence of corporate group advising in the day-to-day operations of tax practice. Recent decisions and comments by the ATO have placed corporate groups and their tax structures and transactions under increased scrutiny and review. Accordingly, practitioners and in-house taxation advisers need to be fully appraised of current trends and interpretations.