Statutory demergers ― overview

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Statutory demergers ― overview

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
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This guidance note gives an overview of the steps and tax implications of a statutory demerger. For an overall introduction to demergers, see the Demergers ― overview guidance note.

Key considerations with statutory demergers

One of the key aspects when carrying out a demerger, from a tax perspective, is to mitigate or avoid any tax charge from splitting up the business or group.

Statutory demergers (also referred to as exempt demergers) are often a more straightforward mechanism, especially from a legal perspective. They also provide businesses with a mechanism to demerge in a tax efficient manner, but because of the strict conditions that must be met the application of statutory demergers is limited. For example, the statutory demerger route cannot apply to non-trading businesses or where arrangements are in place at the time of the demerger to sell the demerged or successor company. In addition, there are rules (the chargeable payments rules) that can result in a tax charge if certain events take place within five years after a statutory demerger. In practice, these rules can

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  • 01 Jul 2026 13:00

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