| Commentary

56.1 Deferment of gain

| Commentary

56 Company reorganisations1

56.1 Deferment of gain

Deferment of the gain is allowed where demerger relief for exempt distributions on a direct demerger (that is a distribution of shares directly to shareholders) has been obtained under the Corporation Tax Act 20102. In other cases, the following conditions must be satisfied before deferment is allowed3:

  1. 56.1.1

        an arrangement is entered into between a company (company A) and its shareholders or debenture holders (or any class of them) for the purpose of, or in connection with, a scheme of reconstruction;

  2. 56.1.2

        under the arrangement, a second

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