Commentary

D6.520 Overview of the tax issues for international takeovers and mergers

Corporate tax
Corporate tax | Commentary

D6.520 Overview of the tax issues for international takeovers and mergers

Corporate tax | Commentary

Takeovers and mergers—international aspects

D6.520 Overview of the tax issues for international takeovers and mergers

Most international mergers involving UK companies involve share for share transactions. Mergers could, however, be effected through transfers of businesses and the reliefs detailed at D6.521–D6.532 may be of note1.

The treatment of any consideration (eg cash, loan note share consideration etc) received by a UK shareholder on a takeover/merger with a non-UK resident company is as detailed at D6.407A–D6.411.

There will, of course, be differences in relation to the treatment of future dividends for UK shareholders holding shares in a non-UK resident company compared to

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