Advanced Tax Aspects of Reorganising the Family Company/Group
This course builds on "Tax Aspects of Reorganising the Family Company/Group".
It looks at application of the Substantial Shareholding Exemption both in the context of the s110, IA 1986 reorganisation and the s213, ICTA 1988 demerger and also in preparatory intra group reorganisations.
It will also look at the availability of Business Property Relief for inheritance tax and the availability of Entrepreneurs' Relief for capital gains tax. Other areas to be covered are corporate debt, the transfer of intangibles and SDLT and Stamp duty.
What You Will Learn
The following issues will be covered in the context of a section 110 reorganisation and a section 213 demerger of family companies/groups.
- Substantial shareholding exemption: when it applies, when it doesn't
- Intra-group reorganisations
- IHT Business Property Relief
- CGT Entrepreneurs' Relief
- Dealing with intra-group debt
- Transferring intangibles
- SDLT and Stamp duty
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