Summary of main types of company reorganisation

By Tolley

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

  • Summary of main types of company reorganisation
  • Demergers
  • Reconstructions
  • Reduction in share capital
  • Purchase of own shares
  • Transfer of a trade

This guidance note summarises some of the ways in which companies may reorganise their activities and some of the key tax considerations.


Groups may want to split out their activities for many different reasons. There may be conflicting interests between shareholders, legal reasons to separate a trade out from the rest of the group with corporate protection, or it may be the only way for a purchaser to be able to buy certain parts of the business.

The term 'demerger' covers several possible structures:

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