| Commentary

270.1 Introduction

| Commentary

3: ISSUES ARISING FOR THE TRANSFERRING OR DISTRIBUTING COMPANY

(a) Corporation tax on chargeable gains

270 Corporation tax on transfer of business

270.1 Introduction

In most cases of company reconstruction, the transferor company will be transferring the whole, or part, of its undertaking (meaning its business or trade) to another company1. The exceptions are direct demergers (where the transferor company transfers shares in its subsidiary company in specie to its own shareholders)2 and the type of indirect demerger where the transferor transfers the shares in its subsidiary company to a company incorporated for the purpose in

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