This paper looks at the scope for 'self-help solutions' to the effective repeal of the loss grouping system. Prior to the enactment of these rules, tax advisers well understood some of the options for income equalisation within a corporate group - how did they do it? How many of those strategies are still available in the face of:
- arm's length pricing rules - for income derived from associates, for expenses incurred to associates, for measuring the cost base of assets and the capital proceeds of sales
- the impact of the new debt-equity rules on options involving corporate financing opportunities
- the 'stop loss' rules
- the surviving rollover rules and where they can help
- and how does Part IVA fit into all of this?
- arm's length pricing rules - for income derived from associates, for expenses incurred to associates, for measuring the cost base of assets and the capital proceeds of sales
- the impact of the new debt-equity rules on options involving corporate financing opportunities
- the 'stop loss' rules
- the surviving rollover rules and where they can help
- and how does Part IVA fit into all of this?