Finance is considering further significant changes to the foreign demerger rules

Proposed amendments to the foreign demergers rule in s. 15(1.4)(e) disappeared when most of the balance of the 2016 technical amendments were put in Bill form and enacted. Some issues were identified with the s. 15(1.4)(e) amendments and Finance did not proceed with them - but intends to do so once it has made further changes. Whether they are left in s. 15 or reformulated to give them a somewhat different application and scope is still under discussion.

Neal Armstrong. Summary of Comment on s. 15(1.4)(e) in the 16 May 2018 IFA Finance Roundtable under s. 15(1.4)(e).