Commentary

D6.429 Administration—Clearance procedure for a demerger

Corporate tax
Corporate tax | Commentary

D6.429 Administration—Clearance procedure for a demerger

Corporate tax | Commentary

D6.429 Administration—Clearance procedure for a demerger

There are three circumstances in connection with a demerger where application for clearance may be made to HMRC in advance of a proposed transaction:

  1.  

    (a)     a company which is proposing to make a distribution as part of a demerger operation may apply for confirmation that the distribution will be an exempt distribution1;

  2.  

    (b)     a company which is proposing to make a payment which might be a chargeable payment may apply for confirmation that the payment will be made for genuine commercial reasons and that it does not form part of a tax avoidance scheme2;

  3.  

    (c)     a company which becomes or ceases to be

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