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  Miscellaneous 2009

The continuity of ownership test under Division 165

Source: Victoria

Published Date: 27 May 2009

 

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This paper covers the continuity of ownership (COT) under Division 165, including:

  • the differences in testing for tax losses, net capital losses and bad debt deductions
  • the concepts of voting power, dividend rights and capital rights, and how they raise difficulties for companies with multiple classes of shares
  • how the same share rule can make it more difficult to utilise a loss (together with the saving exception to the rule)
  • when it is "reasonable" in tracing ownership to conclude that the COT has been satisfied.
Author(s)

Individual Session

The continuity of ownership test under Division 165

Author(s): Andrew Van Dinter ATI , Brian Lane
Materials from this session:

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