Post-Implementation Review into Certain Aspects of the Consolidation Regime

The Chairman of the Board of Taxation, Mr Dick Warburton AO, today announced the release of a position paper on the Board’s post‑implementation review into certain aspects of the consolidation regime.

The Government announced on 3 June 2009  that it had asked the Board to undertake a post‑implementation review of certain aspects of the consolidation regime. The aspects of the consolidation regime that are subject to the review are:

  • The operation of the single entity rule;
  • The operation of the entry history rule in acquisition cases; and
  • The interaction between the consolidation provisions and other parts of the income tax law.

To facilitate public consultation, the Board released on 9 December 2009 a discussion paper and subsequently received 12 submissions.  The position paper sets out the Board’s considered views on the issues raised in the discussion paper and in stakeholders submissions.

The Board welcomes submissions on the positions and questions raised in the position paper. The closing date for submissions is Friday 26 November 2010. Submissions may be sent to:


Facsimile: (02) 6263 4471

Post‑implementation review into certain aspects of the consolidation regime
The Board of Taxation
c/- The Treasury
Langton Crescent

While submissions may be lodged electronically or by post, electronic lodgement is preferred.  For accessibility reasons, please submit responses sent via email in a Word or RTF format.  An additional PDF version may also be submitted.

Please note if your submission does not indicate it is to be treated as confidential, it could be posted on the Board of Taxation’s website at some time in the future.

Copies of the Board’s position paper are available from Printed versions of the paper are available by email request sent to, or by phoning the Board of Taxation Secretariat on (02) 6263 4366.

Further information on the review is available on the Board of Taxation website,


Vernon Joice
Board of Taxation Secretariat
Telephone (02) 6263 4369

Jorge del Busto
Board of Taxation Secretariat
Telephone (02) 6263 4365