The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:
The consideration paid by a purchasing company to the shareholder(s) for their shares in a target company could be in the form of either:
•a mixture of the above
This guidance note covers the tax implications of consideration in the form of shares or a mixture of shares and cash. For details on the tax implications of consideration in the form of loan notes, see the Loan notes and Qualifying Corporate Bonds (QCBs) and non QCBs guidance note.
The timing of the consideration also needs to be considered. Consideration may be paid straight away or it may be deferred. Deferred consideration may be fixed or the amount may be variable. For more information on these, see the Tax treatment of earn-outs and deferred consideration guidance note.
Share for share exchange
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