Made for all practitioners working in this increasingly important area of UK taxation
Covering issues relevant to all size of transaction or company, Taxation of Company Reorganisations, Fifth Edition, includes guidance to a variety of topics from the reduction of capital rules, to using them for tax structuring, to EU cross-border transactions. The previous edition was published in 2012 and this new version brings the reader up-to-date with a range of legislative changes, new cases and the authors' collective experience in helping their clients deal with this.
Aims to be all things to all tax advisors
This title is an essential reference source for tax advisors who need to offer clear and concise guidance to their clients through basic rules, reorganisations, deemed reorganisations, reconstructions, mergers, demergers and branch incorporations. Written by authors with over fifty years of experience dealing with clients ensures this title is applicable to a wide range of organisations; from small owner managed businesses up to the largest public companies.
What this title includes
Fully updated and revised for key legislative changes
Important cases updates, including Hancock TC 03816 on the application of s116 TCGA
Qualifying Corporate Bonds (QCBs) and non-QCBs
Changes to company law for companies reducing capital.
Relevant sections are bought into line with recent changes to Stamp Duty Land Tax
New guidance on the reduction of capital rules and using them for tax restructuring
Updated instruction on EU cross-border transactions, based on real-life experience
All text reviewed and revised where appropriate, including changes following comments from readers
Clear analysis of all relevant legislation, including the technical and practical consequences of commercial transactions
Background history into Tax Law
Pete Miller, CTA (Fellow), Partner, The Miller Partnership Pete Miller has nearly 25 years' experience in tax, covering all aspects of business and corporation tax issues. Pete founded The Miller Partnership in 2011 to offer expert advice on all business tax issues to other advisers, particularly lawyers and accountants. Specialist areas include reorganisations and reconstructions, the substantial shareholdings exemption, transactions in securities, HMRC clearances, disguised remuneration, taxation of intangible assets and the new patent box legislation. George Hardy is a Financial Services Tax Partner of Ernst & Young LLP and head of their Financial Services Mergers and Acquisition Tax Practice. He is a contributor to many publications.
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