Taxation of Company Reorganisations: 5th Edition

ISBN-13: 9781780438641 / Angielski / Miękka / 2016 / 672 str.

George Hardy

Opis

Taxation of Company Reorganisations covers issues relevant to all size of transaction or company in the UK. The book includes guidance to a variety of topics from the reduction of capital rules and using them for tax structuring to EU cross-border transactions. It will guide the reader through basic rules, reorganizations, deemed reorganizations, reconstructions, mergers, demergers, and branch incorporations. Written by authors with over 50 years of experience dealing with clients ensures this book is applicable to all, from UK small owner managed businesses up to the largest public companies.

Spis treści

Introduction Part 1: Basic rules Chapter 1: Corporation tax and chargeable gains Chapter 2: Stamp taxes Chapter 3: Value added tax Chapter 4: EU Legislation Part 2: Reorganisations Chapter 5: Introduction to reorganisations Chapter 6: Reorganisations of share capital Chapter 7: Conversions of securities Part 3: Deemed reorganisations Chapter 8: Introduction to deemed reorganisations Chapter 9: Share-for-share exchanges Chapter 10: Exchanges involving QCBs Chapter 11: Earn-outs Chapter 12: Interaction with substantial shareholdings exemption Chapter 13: Interactions with other legislation Chapter 14: Reorganisations: Anti-avoidance and clearances Chapter 15: Clearances Part 4: Reconstructions Chapter 16: Introduction to reconstructions Chapter 17: Definition of ‘reconstruction’ Chapter 18: Company compromises or arrangements Chapter 19: The UK reconstruction reliefs Part 5: Mergers Chapter 20: UK company mergers Chapter 21: Cross-border mergers Part 6: Demergers Chapter 22: Introduction to demergers Chapter 23: Demergers: Legal background Chapter 24: Liquidation distributions Chapter 25: Exempt distributions Chapter 26: ‘Return of capital’ demergers Chapter 27: EU cross-border demergers Part 7: Branch incorporations Chapter 28: Incorporation of non-UK branches Chapter 29: EU branch incorporations