Senior associate Peter Scott has written an article for the Australian Tax Forum journal, where he highlights key areas of uncertainty in Australia’s tax consolidation regime.
The article considers the scope and limits of the ‘single entity rule’, which affects all members of tax consolidated groups, with a particular focus on the comments of Pagone J (and Davies J) in Channel Pastoral Holdings Pty Ltd v CoT (2015) 232 FCR 162 and Davies J’s recent comments in Glencore Investment Pty Ltd v CoT [2019] FCA 1432 (subject to appeal).
The Australian Tax Forum is a prestigious quarterly journal published by the Tax Institute with the objective of providing discussion on issues in tax policy, law and reform amongst tax professionals.
To read the full pdf article, click here. To read it on the Tax Institute website, click here.
