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Liquidation Procedures In Tax Structuring

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

 
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
 
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