Corporation Tax

Reorganisations / reconstructions ― IFAs

Produced by Tolley
  • 02 Nov 2021 09:20

The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Reorganisations / reconstructions ― IFAs
  • Reconstructions / demergers
  • Conditions
  • EU cross-border transfers of business ― EU Mergers Directive
  • Transfer of a UK business

Reorganisations / reconstructions ― IFAs

Reliefs for reorganisations and reconstructions are available in respect of intangible fixed assets with rules that effectively provide the same reliefs which are available for assets within the scope of corporation tax on capital gains.

Reconstructions / demergers

Any intangible fixed assets transferred as part of a company reconstruction, including a demerger, involving the transfer of a business or part of a business are treated as transferred on a tax-neutral basis. This operates in the same way as for an intra-group transfer. The rules on intra-group transfers take precedence if the reconstruction involves a transfer within a group.


The conditions for the tax-neutral transfer are that:

  1. there is a scheme of reconstruction involving the transfer of the whole or part of the business from one company to another (see the Reconstructions involving transfer of business guidance note)

  2. the t

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