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Divide and conquer: the partition demerger story

Untangling a business from a group (or single entity) in a tax neutral fashion takes time and care. Colin Askew, Matt Cummings and Alisha Kouser (Eversheds Sutherland) provide a case study considering the tax issues on a partition demerger.

A demerger in a simple sense is the corporate mechanism of separating business streams or divisions. In circumstances where one company holds several business streams demergers are a helpful tool to separate out such streams.

Commercial drivers behind a demerger include the following:

  • Increasing the value of the company: a demerger may allow for a company to realise the full value of each business stream. This is relevant particularly where each stream of the company does not share the same business goals therefore a demerger allows each business stream to pursue its independent strategies to meet its long-term goals.
  • Managing business growth: where one company holds several business...

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