Tax Issues in Corporate Restructuring

Course Overview

This seminar has the objective of introducing to delegates the strategies that might need to be adopted where the split of a company is required in preparation for a business sale either to the management or to third parties, or prior to a flotation.

Other reasons for the demerger or reconstruction might be to resolve a dispute between shareholders wishing to go their separate ways, or to protect a group’s trading company status.

It is desirable that delegates have a sound understanding of the basic principles of company and shareholder taxation.

Course Content

Hiving down the target trade

• Protecting losses when hiving down the target trade into a “clean”
• Newco
• Capital gains implications
• Stamp duty land tax implications

Statutory demerger relief

• The 3 statutory demerger scenarios, and when each is appropriate
• Circumstances when demerger relief would not
• Capital gains implications
• Stamp duty implications
• Clearance procedure and problem areas

Reconstructions under s110 of the Insolvency Act

• Circumstances when a reconstruction under S110 may be needed instead.
• Capital gains implications
• Stamp duty implications

Share buy back as an alternative

• Using the purchase of own shares rules to buy out shareholders
• Tax treatment of corporate shareholders
• Tax treatment of individual shareholders

Delivering this course in-house for you to a number of participants could be very cost effective. Please call us on 020 7387 4484 to discuss this further.

If you have any questions about this seminar please write to us at post@redcliffetraining.co.uk.