Commentary

D6.443 Company taxation following a management buy-out

Corporate tax
Corporate tax | Commentary

D6.443 Company taxation following a management buy-out

Corporate tax | Commentary

D6.443 Company taxation following a management buy-out

There are two main taxation aspects for Newco to consider during the transaction.

The first is the timing and deductibility of interest payments to facilitate the transaction and secondly, the future timing and amounts of corporation tax payments.

Interest payments in a management buy-out

The transfer pricing legislation1 can result in part of the interest costs arising on funding the transaction being non-deductible for corporation tax purposes. Broadly, the rules apply to financing arrangements if a number of persons act together in relation to the financing arrangements of a business, and collectively those persons

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