Tax Aspects of Corporate Reconstructions - M&A’s, Demergers & More

Introduction

The taxation of corporate transactions is complex but, if properly understood, can ensure that commercial transactions are not encumbered by unwarranted tax liabilities.

This in-person full-day course will take you through the tax rules for company reorganisations, mergers and demergers and other forms of corporate and group reconstructions and demonstrate how they work in practical situations.

What You Will Learn

This course will cover the following:

• Reorganisations
  • What is a reorganisation of share capital?
  • Bonus issues and rights issues
  • Reductions of capital
• Share exchanges
  • Share-for-share exchanges
  • Share-for-debenture exchanges
  • Qualifying corporate bonds and non-qualifying corporate bonds
  • Management buy-outs demystified
  • Interactions with other taxes
• Schemes of reconstruction
  • Brief history
  • Definitions of reconstructions
• Degrouping rules
  • Brief history
  • How the rules work
  • Interaction with share exchanges
  • Interaction with schemes of reconstruction
• Demergers
  • What is a demerger?
  • Mechanisms
    • Liquidations
    • Exempt distributions
    • Reductions of capital
• Other aspects
  • Stamp duty issues
  • Stamp duty land tax issues
  • HMRC clearances