Commentary

D6.535 Dual-headed merger structures

Corporate tax
Corporate tax | Commentary

D6.535 Dual-headed merger structures

Corporate tax | Commentary

D6.535 Dual-headed merger structures

A dual-headed structure allows two companies to combine their operations and yet retain a degree of separation. This is achieved by retaining the merging companies as separate legal entities but putting in place arrangements to ensure that the group, as a whole, operates as if it were a single enterprise. This achieves certain political, commercial and tax advantages that may not be obtained with a conventional merger.

Dual headed structures usually consist of the two merging companies ('top-tier companies') with the combined group organised beneath in one of three different ways.

The first (and most common) is

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