Don’t get burned on the churn

James Macky and Steve Plant discuss new tax consolidation rules that can disadvantage taxpayers.

Warning! The new churning rules, introduced when the Treasury Laws Amendment (Income Tax Consolidation Integrity) Act 2018 received Royal Assent on 28 March 2018 but effective for group restructures occurring after 14 May 2013, can significantly disadvantage taxpayers. Broadly, the churning rules can apply when a consolidated group acquires a new subsidiary member (the Target) from a foreign related company, where that foreign related company was able to disregard any gain or loss made on th...

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Authors: James Macky, Steve Plant

Published Date: 20 April 2018