The Deputy Commissioner of Taxation has formally refused a request from AMA Group Limited for demerger relief in connection with a demerger and acquisition transaction involving private equity firm Blackstone casting doubt on the availability of capital gains and income-tax relief for transactions ...

Encouraging share ownership by non-executive directors through non-executive director share rights plans is set to increase following a recent ATO class ruling. ...

The Federal Government has proposed to introduce two new forms of collective investment vehicle – each a shiny, tax-neutral alternative to the unit trust. ...

Stapled structures have been used as an investment platform in the property and infrastructure sectors for decades and more recently have been deployed into renewable energy agriculture and other areas Through the issue of its Taxpayer Alert on stapled structures on 31 January 2017 the ATO indicated ...

Avid readers of Unravelled over the past few years cannot have failed to notice that there are moves afoot to introduce two new forms of collective investment vehicle each promising a shiny tax-neutral alternative to the unit trust and hopefully saving Australian lawyers a lot of sleepless nights ...

Treasury has released for consultation exposure draft legislation to introduce new rules to neutralise the effects of hybrid mismatch arrangements in accordance with Action Item 2 of the OECDG20 Base Erosion and Profit Shifting Project Multinational groups with cross-border arrangements or proposing ...

The Federal Governments Tax Discussion Paper presents a mix of new and old themes for debate about the taxation of Australian business and begins a new stage in tax reform Partner Martin Fry and Senior Associate Jennifer Richards comment on some of the key issues for corporate taxpayers in ...

Corporate mergers and acquisitions commonly involve changes to entities that comprise a corporate group the holding of property within that group and the ultimate beneficial ownership of that group Even if those changes occur entirely outside Australia Australian landholder duty may be payable and ...

A recent draft tax ruling may make it more difficult for employers to claim tax deductions for contributions made to employee remuneration trusts However the ruling is expected to have limited practical application to listed companies making non-refundable contributions to traditional employee share ...

In an important ruling the High Court has decided that a purchaser of leased premises will make a supply of the leased premises when after completion the purchaser observes its express obligations under the lease The decision provides much-needed certainty for vendors and purchasers of leased ...