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Demergers

Richard Harbot, Associate, Berwin Leigton Paisner, looks at the four main structures used to facilitate a demerger and their treatment for tax purposes, focusing in particular on the Section 110 Scheme

 
Richard Harbot Associate Berwin Leigton Paisner looks at the four main structures used to facilitate a demerger and their treatment for tax purposes focusing in particular on the Section 110 Scheme
 
The term 'demerger' is used to describe a segregation of business activities to one or more companies. There are various structures which can be used to facilitate a demerger and each has a different treatment for tax purposes. The four main structures are:
 
●     direct demerger or straight dividend route;
 
●     indirect demerger or three-cornered demerger;
 
●     Companies Act...

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