UNSW LAW : ATAX0418 - Consolidations and Group Structures

None

Units of Credit: 6

Description

This course deals with taxation of structures consisting of multiple 'vehicles'. It covers companies, partnerships and trusts operating in conjunction with one another and large corporate groups. This includes group consolidation. The course is designed to take you beyond a static consideration of the taxation of companies, partnerships and trusts in isolation, to a consideration of the 'synergies', the opportunities, the complexities, the problems, arising from their interaction. It pays particular attention to the operation of legal formalism and the general anti-avoidance provisions in Part IVA on these structures. It looks at intra-group and extra-group transactions. It looks at the new consolidation regime and other proposals for changes.

Objectives

This course aims to:

Provide an understanding of tax consolidation within groups in terms of what the rules are and what their purpose is
Offer a tax-orientated treatment of partnerships and joint ventures
Introduce students to 'complex structures' (ie, structures consisting of multiple vehicles, corporate groups)
Develop analytical skills, and both a practical and theoretical understanding of the principles governing the choice and structures of entities to be used for the purpose of trade or investment.

Main Topics

Corporate tax planning: Case studies
Anti-avoidance (inc legal formalism)
Consolidated groups (inc losses & reconstruction)
Non-consolidated groups
Capital profits