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  • Commercial deals

    We engage early with privately owned and wealthy groups to offer a pre-lodgment compliance agreement for commercial deals and restructure events. We define a commercial deal as any significant business transaction that may affect the structure of your business. Some examples of this may include:

    • demergers
    • divesting
    • financing and refinancing
    • initial public offerings
    • mergers and acquisitions
    • private equity
    • restructures
    • sale of business (partial or complete) or business assets
    • sale of commercial property
    • share buybacks
    • takeovers.

    You can use our early engagement service to receive practical certainty for these significant events while they are being planned or before lodgment.

    Our commercial deals service is distinct from our early engagement for advice service whereby you can engage early with us if you are considering applying for formal advice, such as a private ruling.

    Media: The Commercial Deals Early Engagement Program Link (Duration: 3:09)

    Next steps:

    You can request a pre-lodgment agreement by:

    Gaining certainty on your commercial deal

    We know your tax and super affairs can be complicated. We want to work with you directly to gain a clear understanding of your circumstances and address any issues for you as soon as possible. You can contact us to seek a pre-lodgment agreement for any commercial deal you are considering or have recently completed.

    If you contact us, we can:

    • help resolve tax technical issues relating to the deal
    • work towards agreement on the tax position you intend to take
    • help you meet your tax obligations and reduce the likelihood of a review.

    We may sometimes approach you about your involvement in a commercial deal or restructure event. Your participation is voluntary, and includes the option of deferring the engagement interactions with us to a more suitable time prior to lodgment.

    Working transparently with us can achieve a mutual resolution of any tax issues arising prior to lodgment. This enables potential tax disputes to be avoided post lodgment.

    If agreement can be reached and lodgement received as agreed, we will not conduct a review or audit for the commercial deal transaction.

    This can increase certainty around how the tax law applies to your individual circumstances.

    Approach us pre-deal

    We can look over your proposed deal and discuss the tax implications of the proposed transactions. If time allows before the deal is completed we can provide practical certainty on the tax outcomes of the proposed deal.

    Approach us pre-lodgment

    When you have completed a deal, we can work with you to reach an agreement as to how and when the transaction will be reported for tax purposes. However, we may still contact you post-lodgment to confirm that you reported as agreed.

    Engage with us

    It is best to engage with us as early as possible to discuss your commercial deal and work with us to get your tax position right before you lodge your tax return. By doing so, you can avoid potential tax disputes that can occur post-lodgment as well as penalties and interest where amendments are required to correct reporting.

    You can request a pre-lodgment agreement and talk to us about your commercial deal by:

    See also:

    Last modified: 06 Sep 2019QC 57799