Iain Kerr Director M&A Tax KPMG LLP (UK) and Allan Rippon Partner McGrigors LLP consider cross-border mergers and transfers of businesses and how they may be used in an M&A context
Since December 2007 it has become easier to merge UK companies into EEA companies and EEA companies into UK companies.
New UK tax reorganisation reliefs have been introduced that may apply to such mergers to make them tax-neutral. In addition the same tax reorganisation reliefs apply for cross-border transfers of businesses hence extending the previous tax reliefs which only applied to cross-border transfers of trade. These rules apply from 1 January 2007 so could apply to previous transfers of businesses from this date if the conditions were satisfied.
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Iain Kerr Director M&A Tax KPMG LLP (UK) and Allan Rippon Partner McGrigors LLP consider cross-border mergers and transfers of businesses and how they may be used in an M&A context
Since December 2007 it has become easier to merge UK companies into EEA companies and EEA companies into UK companies.
New UK tax reorganisation reliefs have been introduced that may apply to such mergers to make them tax-neutral. In addition the same tax reorganisation reliefs apply for cross-border transfers of businesses hence extending the previous tax reliefs which only applied to cross-border transfers of trade. These rules apply from 1 January 2007 so could apply to previous transfers of businesses from this date if the conditions were satisfied.
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: