Commentary

D6.440 Management buy-out—other tax considerations

Corporate tax
Corporate tax | Commentary

D6.440 Management buy-out—other tax considerations

Corporate tax | Commentary

D6.440 Management buy-out—other tax considerations

One consequence of a company sale transaction is that share options held by employees in Target become exercisable; possibly resulting in an income tax liability for the employees1. Corporation tax relief for the company may however be available (See D1.335)2.

The professional costs incurred on the deal itself may not be deductible for corporation tax purposes as they have a capital purpose, namely the acquisition of a capital asset. It had been held that the professional costs on an acquisition transaction were deductible as management expenses3, and although the management expenses legislation was subsequently amended, costs

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