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Recognising that the revenue system is still in the course of implementing major legislated and announced changes, we continue to work with large business to ensure appropriate support, compliance and administrative arrangements are in place for them to successfully implement and operate these measures. In dealing with reform issues, we acknowledge any complexities of the new rules and adjustments that businesses need to make, while addressing cases where businesses are exploiting areas of uncertainty and seeking tax benefits not intended by the law.
Consolidation
In oversighting the implementation of the consolidation regime, we are examining:
- ownership restructuring
- funding arrangements, function and location before and after consolidation
- significant revaluations of assets as part of consolidating
- the use of franking credits, foreign tax credits and losses
- consolidation notifications, including entries and exits
- consolidation-related disclosures made by corporate groups in their reports to the market or the Australian Securities and Investments Commission - we contact these groups where appropriate
- the calculation of the PAYG rate for the consolidated group
- substantial movements in capital gains and losses, losses more generally, total debt and interest expenses, and capital allowance claims
- international Schedule 25A and thin capitalisation disclosures
- tax reconciliation items, and
- significant transactions to ensure compliance with the general value shifting rules.
In ensuring that arrangements are consistent with the rules and do not involve tax avoidance, we undertake specific enquiries or reviews where appropriate.
Market valuations for consolidation continue to be a focus. We are undertaking reviews to check the appropriateness of market valuations used for forming, entering and exiting consolidated groups, for loss utilisation and for resetting asset values. We are publishing our guidelines to help businesses do their own risk assessment.
We are in the process of issuing a range of public rulings and determinations to assist clients implementing consolidation. As appropriate, we will work with taxpayers to resolve significant consolidation issues they may have before their tax returns are lodged. Depending on the taxpayer's wishes, some issues will be clarified through the private binding rulings process.
Uniform capital allowances
We focus on ensuring that businesses correctly apply the new rules for depreciating assets, particularly where they self-assess the effective life of assets, there are major changes to depreciation claims, or the sale or transfer of intellectual property is involved. We check returns and use external data to identify changes and values of assets. We are also working with industry bodies and large businesses to ensure businesses properly identify, track and calculate the appropriate deductions for their business assets.
Taxation of financial arrangements and corporate financing
We check compliance with new laws for classifying financial arrangements as either debt or equity, for setting limits between levels of debt and equity funding (thin capitalisation), and for the transitional arrangements for the debt to equity rules. We are examining many corporate restructures and changes to pre-existing finance arrangements and will challenge those designed to obtain tax benefits not intended by the law.
The new rules for managing foreign exchange gains and losses are important in the context of cross-border dealings and we check to make sure large businesses are applying them properly.
Review of international tax arrangements
This program includes a range of measures affecting large businesses. Our focus is to ensure that the measures are successfully implemented and that there are appropriate support and compliance arrangements (for more information see international tax issues).
Sections within D. Large business
Last Modified: Tuesday, 11 March 2008