Commentary

D6.101 Reorganisations—overview and scope of the legislation

Corporate tax
Corporate tax | Commentary

D6.101 Reorganisations—overview and scope of the legislation

Corporate tax | Commentary

Part D6     Company reconstruction and profit extraction

Contents of Part D6

D6.1     Corporate reorganisations—general rules

D6.2     Reorganisation of share capital

D6.3     Intra-group reorganisations

D6.4     Takeovers, mergers, demergers, buyouts and other transfers

D6.5     International reorganisations

D6.6     Shareholder return of value and profit extraction

D6.7     Insolvencies and administrations

[D6.8]     [Rewritten—Incorporation and disincorporation]

Division D6.1     Corporate reorganisations—general rules

For updates affecting this Division please see Part D0 Updates

Reorganisations

D6.101 Reorganisations—overview and scope of the legislation

There are several reasons for undertaking a reorganisation of a corporate structure, including, among others, tax planning considerations.

The essential feature of a reorganisation is that overall ownership of the reorganised company or group is

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial