The Australian Taxation Office (ATO) has published Draft Taxation Determination (TD) 2019/D1 - Income tax: what is a 'restructuring' for the purposes of subsection 125-70(1) of the Income Tax Assessment Act 1997? The meaning of 'restructuring' is important in relation to the availability of demerger relief, which requires that there must be a 'demerger' as defined in subsection 125-70(1) of the ITAA 1997, the first element of which is that there is a 'restructuring' of the demerger group.  TD 2019/D1 provides a draft ruling that sets out what constitutes a restructuring for this purpose, as well as several examples. Comments on...