The ideal M&A tax outcome - where shareholders can defer gains (or obtain franked dividends), and companies can avoid gains and increase deductions - was made possible by the various interactions between scrip-for-scrip roll-over, demerger relief, the tax consolidation regime and the imputation system. But has the Assistant Treasurer's press releases of 12 and 16 October 2007 irreparably changed things?
This session considered what has been possible where the right tax reliefs are used in the right order. It also considered some of the tender spots for such M&A transactions - old and new - like those raised by the Assistant Treasurer's recent announcements, and like those associated with the different dividend strategies of the parties.