Given the on-going uncertainty with respect to the taxation of trusts and increasing compliance costs of operating trust structures traditionally utilised by many family “groups”, there is renewed focus on tax consolidation for SME clients. This paper addresses why you would consider adopting the complex tax consolidation rules for certain SME clients and how to steer your way through these complexities.
It covers:
- a brief introduction to tax consolidation and the current state of play
- migrating current structures (eg rollovers of trusts or partnerships to companies, and the interplay between the inherited history and single entity rules)
- forming a consolidated group – the value proposition (advantages and disadvantages of the ACA calculation, including the loss of pre-CGT status and step-up in cost base of depreciable assets)
- accounting for tax consolidated groups – anintroduction to UIG 1052
- distributions to investors (treatment of dividends,loans etc)
- introducing new funding and investors
- leaving a consolidated group (eg CGT event L5and clear exit)
- succession planning.