Commentary

D6.635 New holding company—structure and implications

Corporate tax
Corporate tax | Commentary

D6.635 New holding company—structure and implications

Corporate tax | Commentary

New holding company

D6.635 New holding company—structure and implications

If a company does not have sufficient distributable reserves and/or does not have sufficient share capital or share premium to carry out the various transactions detailed at D6.605–D6.625, then it may want to consider achieving a return of value by creating a new holding company through a scheme of arrangement (D6.426). There are many possible variations. The simplest way to return cash to shareholders would be for the new holding company to issue shares and pay cash pro-rata to shareholders. Alternatively, the new holding company could issue ordinary shares and

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