Its referred to as the 'similar business test' if there is a change in majority ownership. As much as I don't agree with it you could just imagine profitable companies consistently acquiring those entities with significant accumulated losses for cents on the dollar with the intent of utilising the aforementioned losses.
While it would technically disadvantage the taxpayer it would advantage shareholders in cases like this as the tangible and non tangible assets would retain value while the corporate shell would also retain value in its inherent losses all of which could be auctioned off to maximise returns to shareholders.
https://www.pwc.com.au/tax/taxtalk/...ibility-or-continued-uncertainty-13022019.pdf
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