Case study
Property group tax restructure
A multi-entity property group needed consolidation, Division 7A clean-up, and voluntary disclosure before a bank refinance.
We mapped inter-company loans, trust distributions, and land tax grouping. Complying loan agreements were executed before 30 June; voluntary disclosure covered historical UPEs.
Lender credit teams received a consolidation map and loan schedule before refinance drawdown. ATO correspondence was managed through a single chronology memo to avoid conflicting narratives.
| Workstream | Before | After |
|---|---|---|
| Entity count | 6 operating entities | 3 consolidated entities |
| Inter-co loans | Informal balances | Complying loan agreements |
| GST positions | Historical variance | $180k adjustment recovered |
"The refinance would not have proceeded without the consolidation map and loan documentation BDN prepared."
Was voluntary disclosure required?
Yes—for historical positions; we prepared chronology and quantification before lodgement.
Did you replace the tax agent?
No—we advised on structure and documentation; lodgement remained with the group's registered agent.
How long before refinance?
Six weeks from engagement to lender-ready consolidation pack.
Scope of work
Entity mapping, UPE quantification, complying loan agreements, consolidation eligibility, and voluntary disclosure preparation preceded the bank refinance.
Week 1–2
Data room review and inter-company loan schedule.
Week 3–6
Restructure design and board resolutions.
Week 7+
Lodgement support and ATO correspondence.
Bank and ATO coordination
Consolidation map and loan documentation were shared with the lender's credit team; voluntary disclosure was lodged before refinance drawdown.
Discuss a tax restructure
Outline your entity count and transaction driver.