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Consolidations and Group Structures - ATAX0418
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Faculty: Faculty of Law
 
 
School:  Australian School of Taxation
 
 
Course Outline: See below
 
 
Campus: ATAX Campus
 
 
Career: Postgraduate
 
 
Units of Credit: 6
 
 
EFTSL: 0.12500 (more info)
 
 
Indicative Contact Hours per Week: 0
 
 
Enrolment Requirements:
 
 
Restricted to students enrolled in Programs 9250 or 9260 or 9255
 
 
Excluded: ATAX0318, ATAX0518
 
 
Fee Band: 1 (more info)
 
 
Further Information: See Class Timetable
 
 

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.


Recommended Prior Knowledge

None

Course 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

Assessment

1 research paper
1 exam

Course Texts

Prescribed
There is no prescribed textbook for this course.

Acts
You must purchase or have access to the following publications:
  • Income Tax Assessment Act 1936 Income Tax Assessment Act 1997
Citation and Style Guides
The following is a selection of acceptable citation and style guides, which you may use as the basis for your written work. You must purchase or have access to one of the following publications:
  • Rozenberg P, Australian guide to uniform legal citation (Sydney: Lawbook Co, 2nd ed, 2003)
  • Stuhmcke A, Legal referencing (Sydney: Butterworths, 3rd ed, 2005)
  • Australian guide to legal citation (Melbourne University Law Review Association, 2nd ed, 2002) - Available from http://mulr.law.unimelb.edu.au/aglc.asp
Recommended
Below is a list of further references that you may find useful in this course. Purchase of recommended references is not compulsory. Selected references may be borrowed and dispatched to you through the Atax Book Borrowing Service (ABBS). This service will replace the Library collections previously held in Learning Centres.
  • Cashmere M, Tax and Corporate Financing into the New Millennium (CCH, 1999)
  • Magney T & Scholtz W, Tax Planning for Business (Butterworths, 1995)
  • Hamilton, Deutsch & Raneri, Guidebook to Australian International Taxation (Prospect, 6th student edition, 1999)
  • Consolidation reference manual (Nat 6835) at http://www.ato.gov.au/large/content.asp?doc=/content/34764.htm

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© The University of New South Wales (CRICOS Provider No.: 00098G), 2004-2011. The information contained in this Handbook is indicative only. While every effort is made to keep this information up-to-date, the University reserves the right to discontinue or vary arrangements, programs and courses at any time without notice and at its discretion. While the University will try to avoid or minimise any inconvenience, changes may also be made to programs, courses and staff after enrolment. The University may also set limits on the number of students in a course.