The Australian Taxation Office (ATO) has published guidance on Tax consolidated group restructures and transition rules, which explains how Australia’s Pillar 2 minimum tax rules treat acquisitions, restructures, and other ownership or asset transfers involving tax consolidated groups. In particular, the guidance covers the following:
- Restructure rules and transition rules for tax consolidated groups
- Section 9-5: Baseline transition rule
- Subsection 9-5(3): Baseline integrity rule
- Section 9-…