Commentary

D6.437 Management buy-out—vendor tax position on a part disposal of the business

Corporate tax
Corporate tax | Commentary

D6.437 Management buy-out—vendor tax position on a part disposal of the business

Corporate tax | Commentary

D6.437 Management buy-out—vendor tax position on a part disposal of the business

Where circumstances are such that it is not desirable for all of the Target company to be included in the buy-out, it is possible to either undertake some corporate restructuring or simply do an 'assets' sale for the assets to be bought out.

In a large group of companies a pre-sale reorganisation should not prove too difficult to achieve, as assets could be transferred out of Target to another group company on a tax neutral basis under the various group reliefs see Division D2.3.

However, in the case of a

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