Demergers

View Tax by content type:

Latest Tax News

Featured Tax content

Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
Read More >
Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
Read More >
Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
Read More >
19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
Read More >
Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
Read More >
Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
Read More >
19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
Read More >
19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
Read More >
Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
Read More >
19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
Read More >
19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
Read More >
Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
Read More >
19th May
Practice notes
Why have a tax covenant?It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a...
Read More >
19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
Read More >
Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
Read More >
19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
Read More >
19th May

Most recent Demergers content

Practice notes
Insolvency Act 1986 s 110 arrangementsThis Practice Note covers: •what arrangements under Insolvency Act 1986 (IA 1986), s 110 (a s 110 arrangement)...
Read More >
Produced in partnership with Phillip Taylor of Sidley Austin LLP and Chris Laughton of Mercer & Hole Chartered Accountants 18th Aug
Q&As
Does the existence of subscriber shares prevent capital gains reconstruction relief from being available on a demerger?Most demergers (liquidation...
Read More >
16th Aug
Q&As
Is stamp duty payable in respect of a share for share exchange undertaken as part of a section 110 demerger? Since UK stamp duty applies to...
Read More >
16th Aug
Q&As
In a liquidation demerger involving a hive-up of assets to a ‘Liquidation Holdco’, does a capital gains degrouping charge arise?The capital gains...
Read More >
16th Aug
Practice notes
Statutory demergersThis Practice Note is about the tax implications of a statutory demerger.It is possible to carry out a demerger by a company (the...
Read More >
15th Aug
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
Read More >
Produced in partnership with Zoe Feller of Bird & Bird 15th Aug
Practice notes
Demergers—an introduction to the tax issuesA demerger means the separation of a company’s business into two or more parts, typically carried on by...
Read More >
Produced in partnership with Zoe Feller of Bird & Bird and Robert Langston of Saffery Champness 15th Aug
Practice notes
Statutory demergers—the tax conditionsThis Practice Note is about the conditions that a statutory (ie dividend) demerger, whether direct or indirect,...
Read More >
15th Aug
Practice notes
Statutory demergers—chargeable payments, clearance in advance and returnsThis Practice Note is about the following aspects of the tax rules on...
Read More >
15th Aug
Practice notes
Liquidation demergersThis Practice Note is about the tax implications of liquidation demergers, also known as section 110 demergers, after section 110...
Read More >
15th Aug
Precedents
Clearance letter—statutory demerger[Team Leader][insert HMRC address][insert date]Application for clearance[s] in advance under section 1091 of the...
Read More >
Produced in partnership with Robert Langston of Saffery Champness 15th Aug
Precedents
Clearance letter—TCGA 1992, ss 138 and 139(5), ITA 2007, s 701 and CTA 2010, s 748[Team Leader][insert HMRC address][insert date]Application for...
Read More >
15th Aug

Popular documents