Demergers are complex corporate transactions that aim to split two or more businesses into separate ownership. Under UK tax and company law it may be possible to achieve a tax-neutral demerger through the use of a statutory demerger (direct or indirect) a s 110 liquidation demerger or a capital reduction demerger. Other simpler methods may also be possible where mathematically the taxes arising are minimal.
Demergers – arguably one of the most complex types of corporate transaction – become even more complicated when international elements are involved. International aspects do carry additional risk but they can also create opportunities. The important point is that the implications of undertaking a demerger with international aspects must be fully and specifically considered.
Common international aspects that...
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Demergers are complex corporate transactions that aim to split two or more businesses into separate ownership. Under UK tax and company law it may be possible to achieve a tax-neutral demerger through the use of a statutory demerger (direct or indirect) a s 110 liquidation demerger or a capital reduction demerger. Other simpler methods may also be possible where mathematically the taxes arising are minimal.
Demergers – arguably one of the most complex types of corporate transaction – become even more complicated when international elements are involved. International aspects do carry additional risk but they can also create opportunities. The important point is that the implications of undertaking a demerger with international aspects must be fully and specifically considered.
Common international aspects that...
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