Commentary

260 Reorganisations and reconstructions

COMPANIES vol 11 acquisitions, mergers, demergers
| Commentary

260 Reorganisations and reconstructions

| Commentary

260 Reorganisations and reconstructions

The various company reorganisations as defined in the tax legislation which are designed to avoid tax issues arising at the moment of reorganisations, and for which advance clearance procedures are available, are:

  1. 260.1

        demergers and exempt distributions under the Corporation Tax Act 2010 Section 1075, whereby trading activities carried on by either a group or company are transferred directly to their shareholders;

  2. 260.2

        share-for-share exchanges under the Taxation of Chargeable Gains Act 1992 Section 1351;

  3. 260.3

        schemes of reconstruction involving the issue of securities under the Taxation of Chargeable Gains Act 1992 Section 1362;

  4. 260.4

        schemes

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