Tax Aspects of Reorganising the Family Company/Group

Introduction

Whether it is shareholders falling out, a desire to introduce external finance or an offer for the family business, the existing group structure may not be what your client wants or needs.

Using a series of examples, this in-person seminar examines the two most used methods of reorganising a group, the section 110, Insolvency Act 1986 reconstruction and the section 213, ICTA 1988 demerger.

It will examine the ways in which a group can be restructured using the available reliefs to maximise the return to shareholders whilst avoiding the pitfalls.

This intermediate level seminar will also examine the relevant Company Law applicable to reorganisations.

What You Will Learn

• The commercial rationale to reorganise
• Building blocks: a detailed examination of the relevant statutory provisions
• Section 110, IA 1986 reconstructions: reorganisations, partitions and other variants including liquidating the holding company and using a conduit company to avoid liquidating a holding company
• An examination of HMRC clearances
• Section 213, ICTA 1988 demergers
• Recent case law