Demergers

Demergers guidance:

FORTHCOMING CHANGE on amendments to FA 1986, s 77A: Finance Bill 2019–20 amends, with effect from Royal Assent, section 77A of Finance Act 1986 (FA 1986) to ensure that...

Practice Note

Produced in partnership with Robert Langston of Saffery Champness [Team Leader] [insert HMRC address] [insert date] Application for clearance[s] in advance under section...

Precedents

[Team Leader] [insert HMRC address] [insert date] Application for clearances in advance under [section[s] 138[ and 139(5)] Taxation of Chargeable Gains Act 1992][ and...

Precedents

A demerger means the separation of a company’s business into two or more parts, typically carried on by successor companies under the same ownership as the original...

Practice Note

This Practice Note covers: • what arrangements under Insolvency Act 1986 (IA 1986), s 110 (a s 110 arrangement) is (see: What is a s 110 arrangement?) • the rationale for...

Practice Note

FORTHCOMING CHANGE on amendments to FA 1986, s 77A: Finance Bill 2019–20 amends, with effect from Royal Assent, section 77A of Finance Act 1986 (FA 1986) to ensure that...

Practice Note

This Practice Note is about the tax implications of a statutory demerger. The most straightforward way to carry out a demerger involves a company (the target company)...

Practice Note

This Practice Note is about the following aspects of the tax rules on statutory (ie dividend) demergers: • the anti-avoidance rules concerning chargeable payments, and •...

Practice Note

This Practice Note is about the conditions that a statutory (ie dividend) demerger, whether direct or indirect, must satisfy if it is to qualify as an exempt...

Practice Note
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