Commentary

D6.201 Summary of reorganisation types

Corporate tax
Corporate tax | Commentary

D6.201 Summary of reorganisation types

Corporate tax | Commentary

Division D6.2     Reorganisation of share capital

For updates affecting this Division please see Part D0 Updates

Reorganisation of share capital—overview

D6.201 Summary of reorganisation types

This division details the tax implications arising from corporate reorganisations directly involving the issue of share capital.

As detailed in Division D6.1, such reorganisations are afforded special capital gains tax treatment if they fall within the statutory definition (D6.102) of a reorganisation.

The special tax treatment essentially means that the replacement assets 'stand in the shoes' of the original assets. There is no disposal and reacquisition and the transaction is tax neutral. See D6.103 for details.

Those reorganisations

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