Commentary

Section 263 Winding-up exemption—reorganisations under Insolvency Act 1986 Section 110

COMPANIES vol 11 acquisitions, mergers, demergers
| Commentary

Section 263 Winding-up exemption—reorganisations under Insolvency Act 1986 Section 110

| Commentary

263 Winding-up exemption—reorganisations under Insolvency Act 1986 Section 110

A ‘distribution made in respect of share capital in a winding up’ is excluded from the definition of ‘distribution’ in the Corporation Tax Acts1. Consequently, the issue of shares by Company B to the shareholders of Company A as part of a company reorganisation carried out under Section 110 of the Insolvency Act 1986 will not constitute a distribution to those shareholders for tax purposes2 and instead will be treated as capital.

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