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

TABL5503 Taxation of Corporations and TABL5515 Taxation of Capital Gains are recommended before studying this course. Students without this prior knowledge may find that they need to take steps to ensure adequate understanding of the related area. Note: as some areas of tax law are interrelated in some courses, we recommend that students either have prior knowledge of the related area or study another course in that area concurrently.