The ability of companies to preserve and utilise carry forward tax losses continues to present challenges both for taxpayers and Government Revenue.
This presentation covers:
- current status of proposed loss carry back rules and review of loss rules recommended by Business Tax Working Group report on the tax treatment of losses
- challenges faced by taxpayers in satisfying the “continuity of ownership” and “same business” tests
- losses in the consolidation context, including transfers of losses to the head company of a consolidated group and available fraction calculations
- current ATO compliance activity around loss claims.