- whether the head company needs a funding arrangement - accounting issues and directors' duties
- whether the group needs a Tax Sharing Agreement (TSA) - benefits, directors' duties and relationship to ASIC cross guarantee
- issues in drafting Tax Sharing and Tax Funding Agreements - allocation methodology, liabilities covered, entities covered, dealing with losses and record keeping
- pitfalls in the TSA regime
- how you provide third parties with a level of comfort that the TSA will work.