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 2006 Part 26 scheme; and
● Insolvency Act 1986 s 110 scheme (Section 110 Scheme).
This article provides a...
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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 2006 Part 26 scheme; and
● Insolvency Act 1986 s 110 scheme (Section 110 Scheme).
This article provides a...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
