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  Miscellaneous 2003

In Search of the True Demerger: Boundary Issues with Division 125 seminar

Source: National

Published Date: 22 Aug 2003

 

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This seminar paper examines some of the definitional issues surrounding Division 125, including:
- 20% ownership interest requirement for demerger subsidiary and 'ultimate' head entity in defining demerger group
- methods of demerger restructuring under paragraph 125-70(1)(b)
- Subsection 125-70(2) proportionality requirements
- requirements of paragraphs 45B(8)(a) and (8) (i)
- tax treatment of a non-conforming demerger. Is Division 125 an exclusive demerger code?
- insights into the ATO's administration of Division 125 and section 45B as it relates to demergers.
Author(s)

Individual Session

In Search of the True Demerger

Author(s): Gordon Thring CTA , Martin Keating
Materials from this session:

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