Taxation of Company Reorganisations: Fourth Edition

ISBN-13: 9781847665300 / Angielski / Miękka / 2012 / 662 str.

Opis

This practical day-to-day guide to the tax provisions of commercial reorganizations and reconstructions enables tax practitioners working in this increasingly important area of UK taxation to accurately negotiate their clients' commercial reorganization transactions. This fourth edition is fully revised and updated and covers new UK legislation relating to the latest implementation of EU Directives into UK tax law. The authors provide clear analysis of all relevant legislation, including the technical and practical consequences of commercial transactions, along with information on transactions of all sizes, from major corporate groups to owner-managed businesses. It will be an essential reference source for tax advisers who need to offer clear guidance to client companies that are reorganizing, amalgamating, or demerging.

Spis treści

Introduction; Part 1: Basic rules: Corporation tax and chargeable gains; Stamp taxes; Value added tax; EU Legislation; Part 2: Reorganisations: Introduction to reorganisations; Reorganisations of share capital; Conversions of securities; Part 3: Deemed reorganisations: Introduction to deemed reorganisations; Share-for-share exchanges; Exchanges involving QCBs; Earn-outs; Interaction with substantial shareholdings exemption; Interactions with other legislation; Reorganisations: Anti-avoidance and clearances; Clearances; Part 4: Reconstructions: Introduction to reconstructions; Definition of 'reconstruction'; Company compromises or arrangements; The UK reconstruction reliefs; Part 5: Mergers: UK company mergers; Cross-border mergers; Part 6: Demergers: Introduction to demergers; Demergers: Legal background; Liquidation distributions; Exempt distributions; 'Return of capital' demergers; EU cross-border demergers; Part 7: Branch incorporations: Incorporation of non-UK branches; EU branch incorporations.