The following Tax Q&A Produced in partnership with Mary Ashley of Old Square Tax Chambers provides comprehensive and up to date legal information covering:
A reorganisation of a company’s share capital should be tax neutral for its shareholders. This is because the essential feature of a reorganisation is that the overall ownership of the reorganised company is unchanged in the sense that the identity and proportionate interests of the shareholders remain the same after the reorganisation has been carried out (see Practice Note: Tax treatment of reorganisations of share capital).
What constitutes a reorganisation for tax purposes is specifically defined by statute.
The legislation provides, in section 126(2) of the Taxation of Chargeable Gains Act 1992 (TCGA 1992
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