Reorganisations and tax

Featured guidance
Reorganisations and tax guidance:

HMRC—Stamp Office [insert HMRC Stamp Office address] Application for stamp duty group relief under section 42 of the Finance Act 1930 (as amended) in the matter of a...

Precedents

FORTHCOMING CHANGE relating to transfers within an EU group: Finance Bill 2020 is expected to contain provisions permitting companies to pay tax in instalments in...

Practice Note

[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

HM Revenue and Customs [insert address] [insert date] Election under section 171A(4) of the Taxation of Chargeable Gains Act 1992 This election is made jointly by [insert...

Precedents

Part 14 of the Corporation Tax Act 2010 (CTA 2010) (the Part 14 rules) contains anti-avoidance provisions designed to stop a profitable organisation from reducing its...

Practice Note

This Practice Note is about the meaning of a scheme of reconstruction for tax purposes. Tax neutrality is maintained where a company (company A) enters into an...

Practice Note

Some company acquisitions that involve a corporate buyer will be structured so that the consideration payable is the issue of new shares and/or loan notes by the buying...

Practice Note

This Practice Note is about the tax anti-avoidance rules that apply to a share for share (or share for loan note) exchange or a scheme of reconstruction. Relief from tax...

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

The substantial shareholdings exemption (SSE) is an exemption from corporation tax on chargeable gains for certain share disposals by companies. The exemption does not...

Practice Note

Tax relief for chargeable gains is available for both: • the shareholders of a company, and • the company itself under a scheme of reconstruction provided certain...

Practice Note

The conversion of a company's securities should be treated as a tax neutral reorganisation. The conversion is treated as not involving any disposal of the existing...

Practice Note

This Practice Note is about the meaning of a reorganisation for tax purposes, and the tax treatment of shareholders in a company that undergoes a reorganisation. A...

Practice Note

This Practice Note covers the transactions in securities (TiS) rules relating to the avoidance of both income tax and corporation tax. The TiS rules are potentially...

Practice Note

This Practice Note covers the: • clearance procedure, and • administrative rules (enquiries, counteraction notices and appeals) relating to the anti-avoidance regime...

Practice Note

Sometimes the restructuring of a business will involve a company transferring an existing trade to a different company under the same ownership. Where certain conditions...

Practice Note
Trending Topics
In-House COVID-19