Webb8 apr. 2024 · The shareholders’ continuity test is intended to target situations where loss-making companies are being acquired for tax reasons. Where a substantial change in … Webb25 feb. 2024 · The new business continuity test (BCT) will be added to the Taxation (Annual Rates for 202-21, Feasibility Expenditure, and Remedial Matters) Bill, by way of a …
Shareholder Continuity: Directors’ Knowledge Provision - ird.govt.nz
WebbThe BCT supplements the existing shareholder continuity tax loss carry forward rules with a new “major change” test. It allows losses to be carried forward to future years unless … Webb19 juni 2024 · The rationale behind the rule is to ensure that the group of shareholders who economically incurred the losses are (at least as to 49%) the same group who are able to benefit from those losses in future years when the company has become profitable. In the absence of these rules, various tax loss trading practices could (and previously did) occur. the o\\u0027neil group
Business continuity test - ird.govt.nz
Webb23 apr. 2024 · Shareholder continuity test Losses When a business makes a tax loss, it can be accumulated over time and used to offset profit made in the future. These are known … WebbThe existing shareholder continuity test allows a company to carry-forward its tax losses only if its shareholding remains the same, at least to the extent of 49%. The new business continuity test would be applied as an alternative in the event that the shareholder continuity test is breached. It is a hybrid of the Australian ‘same or similar ... WebbCompanies must pass either a ‘continuity of ownership test’ or a ‘same business test’. This is in s165-10 of the 1997 Act. The company must first be tested for continuity of majority underlying ownership, and if it fails that test, then it can still carry forward and deduct its losses, if it is still carrying on the same business as it did when it failed the continuity of … the o\u0027neil group