When can the FTA restrict a tax group from forming?
The FTA can refuse to allow tax grouping if:
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The transactions between the members are insufficient; there are few or no meaningful transactions amongst members of the tax group.
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Allowing the group to form will make it difficult for the FTA to audit them because the group does not share any common features of an audit.
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Allowing the group to form will result in only one advantage, namely a cash offset benefit.
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Allowing the group to form would add to the workload of the FTA, which includes the points mentioned above as well as others.