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  • Business structure

    Some risks relating to structure and transactions of privately owned wealthy groups that currently attract our attention.

    In this section

    Consolidation issues that attract our attention include inappropriate outcomes from CGT reporting, cost-setting rules, membership and loss utilisation

    We focus on transactions and schemes that exploit the demerger provisions for a tax benefit

    International transactions
    Failure to report or incorrect reporting of international transactions attract our attention

    Lower company tax rate
    We are concerned with ineligible corporate tax entities claiming the concessional tax rate for base rate entities, including artificial or contrived arrangements implemented to access the lower company tax rate

    Professional firms
    We are concerned about individual professional practitioners redirecting their income earned from professional services to an associated entity such that they significantly reduce their tax liability

    Property and construction
    We focus on entities in the property and construction industry incorrectly classifying income and profits from property development activities in their tax returns

    Research and development tax incentive
    We focus on behaviours of concern that result in incorrect research and development (R&D) tax offsets claims with a particular focus on certain industries such as agriculture, mining, software development and property and construction

    Self-managed super funds
    We focus on transactions and schemes that aim to inappropriately take advantage of concessional tax rates that apply to complying super funds

    We focus on risks including complex distributions, non-lodgment of trust and beneficiary tax returns, and trust and taxable income mismatches

    Last modified: 09 May 2022QC 58473