When can the FTA restrict a tax group from forming?
The FTA can refuse to allow tax grouping if:
The transactions between the members are insufficient; there are few or no meaningful transactions amongst members of the tax group.
Allowing the group to form will make it difficult for the FTA to audit them because the group does not share any common features of an audit.
Allowing the group to form will result in only one advantage, namely a cash offset benefit.
Allowing the group to form would add to the workload of the FTA, which includes the points mentioned above as well as others.