This paper focuses on a number of critical issues that we as taxation professionals are facing when advising SME's on whether or not to consolidate:
- should we have formed a group already? There are potentially a number of missed opportunities from not doing so
- tax risks to be considered in structuring a tax consolidated group
- tax consolidation as a strategy for preparing a group for a management buy-in or preparation to a sale of part of the operations
- buying and selling assets vs shares from a consolidated group
- non-tax issues in moving assets around a tax consolidated group for example how effective is asset protection in this situation if a member of the group is subsequently placed in liquidation?
- CGT events and other tax consequences arising from the exit of companies. Quite often some slightly unexpected results can occur
- giving an ‘equity' type interest in a company in the group without breaking the consolidated group.