Removing income tax impediments for business restructures

The Government has announced that it would remove income tax impediments for business restructures.  In particular, these changes:

• provide revenue asset and trading stock roll-overs where interest holders exchange their units in a unit trust for shares in a company;
• broaden beyond consolidated groups the existing revenue asset and trading stock roll‑overs that apply for an exchange of shares in a company for shares in another company;
• ensure integrity by requiring that the roll‑overs only be available where the replacement asset is of the same tax character as the original asset; and
• resolve technical defects relating to certain restructure roll‑overs.

Following public consultation on the policy design of these changes, the Government has prepared an exposure draft of legislation and a draft explanatory memorandum for public consultation on these changes.