261 Potential tax issues

Whilst reconstructions, amalgamations and demergers are radically different in their purpose and effect, the tax position of the following parties will be relevant:

  1. 261.1

        shareholders (who will not wish to be treated as having received a distribution under the Income Tax (Trading and Other Income) Act 2005 and Income Tax Act 2007, nor will they wish to pay capital gains tax under the Taxation of Chargeable Gains Act 1992 as a result of the reorganisation);

  2. 261.2

        a transferor company (which will not wish a charge to tax on any chargeable gains to arise under the Taxation

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