Reorganisations / reconstructions

Produced by Tolley

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

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

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 th

Popular documents