Corporation Tax Guidance

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Company reorganisations and demergers

We have a wealth of tax guidance on company reorganisations and demergers in order that you can provide the most recent and relevant advice.
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Latest Guidance
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28 Jun 2019

This guidance note considers the capital gains tax implications where shares are sold in exchange for new shares.The consideration paid by a purchasing company to the...

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28 Jun 2019

For unquoted trading companies only, the amount received by a shareholder on selling his shares back to the company may be treated as capital, rather than as a...

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28 Jun 2019

This guidance note gives an overview of why and how companies and groups demerge, and the aims and process of tax planning for demergers.There are many reasons why a...

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28 Jun 2019

This guidance note deals with the tax consequences for shareholders and companies involved in a ‘Type 1’ ‘Direct’ Statutory demerger. For an introduction to Statutory...

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28 Jun 2019

Payments by companies to repurchase their own shares are subject either to what is referred to as 'income treatment' or to 'capital treatment'.If the payment is subject...

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28 Jun 2019

In certain circumstances the Statutory demerger route may not be available. For example:•The company does not have sufficient distributable reserves•There are plans to...

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28 Jun 2019

This guidance note summarises some of the ways in which companies may reorganise their activities and some of the key tax considerations.DemergersGroups may want to split...

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28 Jun 2019

The 'paper for paper' rules relating to share for share exchanges are extended to deal with reconstructions. Relief is available to shareholders where there is a...

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28 Jun 2019

Treasury sharesPrior to 30 April 2013, the Companies Acts provided that only a company which was listed on a Stock Exchange (not including AIM) was legally allowed to...

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27 Jun 2019

This guidance note follows on from the Demerger via a liquidation ― overview guidance note which gives an introduction to demergers via liquidations (also known as...

Latest Guidance
Corporation_tax_img5
Corporation Tax

This guidance note considers the capital gains tax implications where shares are sold in exchange for new shares.The consideration paid by a purchasing company to the...

Corporation_tax_img10
Corporation Tax

For unquoted trading companies only, the amount received by a shareholder on selling his shares back to the company may be treated as capital, rather than as a...

Corporation_tax_img
Corporation Tax

This guidance note gives an overview of why and how companies and groups demerge, and the aims and process of tax planning for demergers.There are many reasons why a...

Corporation_tax_img10
Corporation Tax

This guidance note deals with the tax consequences for shareholders and companies involved in a ‘Type 1’ ‘Direct’ Statutory demerger. For an introduction to Statutory...

Corporation_tax_img6
Corporation Tax

Payments by companies to repurchase their own shares are subject either to what is referred to as 'income treatment' or to 'capital treatment'.If the payment is subject...

Corporation_tax_img10
Corporation Tax

In certain circumstances the Statutory demerger route may not be available. For example:•The company does not have sufficient distributable reserves•There are plans to...

Corporation_tax_img
Corporation Tax

This guidance note summarises some of the ways in which companies may reorganise their activities and some of the key tax considerations.DemergersGroups may want to split...

Corporation_tax_img10
Corporation Tax

The 'paper for paper' rules relating to share for share exchanges are extended to deal with reconstructions. Relief is available to shareholders where there is a...

Corporation_tax_img7
Corporation Tax

Treasury sharesPrior to 30 April 2013, the Companies Acts provided that only a company which was listed on a Stock Exchange (not including AIM) was legally allowed to...

Corporation_tax_img9
Corporation Tax

This guidance note follows on from the Demerger via a liquidation ― overview guidance note which gives an introduction to demergers via liquidations (also known as...