Sacha Pertwee Assistant Solicitor in the Corporate Tax Group and Alex Wheeler consider how schemes under Insolvency Act 1986 may be used to facilitate demergers
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 1985 s 425 scheme; and
● Insolvency Act 1986 s 110 scheme (Section 110 Scheme).
The first two of these structures are also referred to...
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:
Sacha Pertwee Assistant Solicitor in the Corporate Tax Group and Alex Wheeler consider how schemes under Insolvency Act 1986 may be used to facilitate demergers
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 1985 s 425 scheme; and
● Insolvency Act 1986 s 110 scheme (Section 110 Scheme).
The first two of these structures are also referred to...
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:
