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James Millar
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Hi Paul

1. I believe the client list “goodwill” (or any significant proportion thereof) would be evaluated as a collective CGT asset. There is no need to analyse dates for each client.

2. The acquisition date of goodwill is actually when you commence creating it which if often on commencement of the business Sect 109-10 ITAA 97

3. Eligibility for the general 50% discount depends on entity type (trusts, individuals and super funds only – not companies).

4. Assuming you do not operate a company (so say a trust), you can often cascade the general 50% 12 month discount and then the remaining SBE concessions to produce a zero tax bill.

These are complex issues so I highly recommend you seek advice. Drop me a line if want prelim thoughts.

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