Commentary

39 General taxation policy on reorganisations

COMPANIES vol 11 acquisitions, mergers, demergers
| Commentary

39 General taxation policy on reorganisations

| Commentary

F: TAXATION

1: TAXATION: GENERAL

39 General taxation policy on reorganisations

Tax legislation includes favourable provisions enabling company takeovers and reorganisations to be effected largely without any adverse tax consequences either for the shareholders or for the companies involved at the point of the reorganisation. The main aim in these circumstances is to render the transaction as far as possible tax neutral. On the other hand, HM Revenue and Customs are aware of the possibilities which company reorganisations provide to disguise artificial tax-avoidance schemes. Therefore, to obtain the favourable tax treatment mentioned above, strict conditions must be satisfied to ensure that the

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