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Taxing joint ventures

Emma Game and Dominic Robertson (Slaughter and May) consider the principal tax issues that can arise when establishing, operating and unwinding a corporate joint venture.
 

Joint ventures (JVs) are an increasingly popular means of achieving commercial goals. They are used for example to pool businesses’ technology (e.g. the Galvani Bioelectronics JV between Alphabet and GSK) as a means of creating scale and synergies while giving both parties an ongoing stake in the upside (e.g. EE before its sale to BT); or simply to create a consortium of investors to purchase an asset.

Whilst JVs can take many forms (including partnerships and contractual collaborations) corporate JVs often the preferred structure for long-term JVs are the focus of this article. Their tax issues can be split between JV formation operation and termination.

Formation

When establishing a JV groups normally pool resources...

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