The Crest of the Commonwealth of Australia Treasury Portfolio Ministers
Picture of Peter Costello

Peter Costello


11 March 1996 - 3 December 2007

Media Release of 28/08/2002




The Treasurer announced today that the Government has accepted a recommendation from the Board of Taxation not to proceed with the Tax Value Method (TVM) and the associated Section 4 'core rules'.

TVM was recommended by the Review of Business Taxation and referred by the Government to the Board of Taxation in August 2000 for consultation and advice. The Board has reported there is significant industry concern about the cost and uncertainty associated with the TVM. In particular, the Board found that there is a widespread perception that, while the TVM may offer benefits in some areas, it would generate greater complexity and uncertainty in others. There is also concern that adopting the TVM would result in substantial transitional costs for tax advisers and business generally.

The Board's recommendation followed an extensive evaluation of the TVM, which included a wide-ranging process of consultation with tax experts, business and the broader community.

While the TVM concept will not be pursued, the Government will develop, in consultation with the business community, a systematic tax treatment of rights and blackhole expenditures, with a view to implementing these changes by July 2005. Until then, the Government will continue to accord appropriate recognition of rights and blackhole expenditures on a case-by-case basis as re-affirmed by the Minister for Revenue and Assistant Treasurer on 14 May 2002 (Maintaining the Momentum of Business Tax Reform).

While much has already been done to address blackhole expenditures through the uniform capital allowance system, some business expenditures remain unrecognised in the tax system. Although rights are currently accorded a range of taxation treatments, anomalous outcomes may arise where there is a gap or overlap between such treatments.

The Government has already, in consultation with the business community, introduced positive measures including thin capitalisation, consolidated taxation of corporate groups, the uniform capital allowances system, tax relief for demergers, and a simplified imputation system. Other ongoing areas of reform which the Government will pursue are the review of international tax arrangements and reforms to the taxation of financial arrangements.

The Board of Taxation was established in 2000 by the Government to ensure full and effective community consultation in the design and implementation of tax legislation. I would like to thank the Board of Taxation for its consultation on and evaluation of the TVM proposal.

28 August 2002

Contact: Niki Savva
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