Commentary

41 Exclusion for reorganisations in the context of a winding up

COMPANIES vol 11 acquisitions, mergers, demergers
| Commentary

41 Exclusion for reorganisations in the context of a winding up

| Commentary

41 Exclusion for reorganisations in the context of a winding up

There is an exclusion from the definition of ‘distribution’ for ‘distributions made in respect of share capital in a winding up’1. Thus, the issue of shares by the acquiring company to the shareholders of the target company in a reorganisation effected under Section 110 of the Insolvency Act 19862 will not constitute a distribution to those shareholders for tax purposes and will be taxed as capital.

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