TD 2019_D1 Submission May 2019.PDF (261 kb)
14 May 2019
The import of the document is that the demerger provisions will not apply in a variety of innocuous situations which, in our view, are meant to be covered by the regime. The TD reaches that view by reasoning that is strained and sometimes inapt. It is hard to resist the conclusion that the issue of the TD, and approach taken in it, reflects an attempt to justify an administrative decision to reverse previous ATO policy, even if it means taking positions that bear little relationship to the Government policy which the legislation embodies. Click the link to read the submission.
Partner, Head of Corporate and M&A