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DEMERGER


Card image Matt Cummings Colin Askew Alisha Kouser
Untangling a business from a group (or single entity) in a tax neutral fashion takes time and care. Colin Askew, Matt Cummings and Alisha Kouser (Eversheds Sutherland) provide a case study considering the tax issues on a partition demerger.
Chris Holmes and Ross Robertson (BDO) explain how international aspects can complicate demergers and what tax issues to look out for. 
Chris Holmes and Ben Handley (BDO) provide a guide to a relatively quick and simple method of separating a company’s activities.
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.
 

Lisa Stevenson (Parisi Tax) answers a tax query a demerger involving the return of capital

Jeanette Zaman and Emma Game (Slaughter and May) consider whether the conditions for demergers to qualify as exempt distributions are in need of an overhaul

Jeff Webber answers a query on whether a loan could be caught as a ‘chargeable payment’ under CTA 2010 s 1088.

Bradley Phillips and Perminder Gainda explain the tax implications of the different types of demerger structures that UK companies typically adopt to split their activities into two or more separate companies, along with a worked example

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