Continuing our series on capital gains relief Robert O'Hare LLM Corporate Tax Group Macfarlanes discusses the nature and application of the regime for reorganisations and reconstructions
Sometimes because it is commercially attractive and occasionally because it is necessary companies restructure their share capital and groups of companies rearrange themselves. Economic ownership is normally unchanged. For UK tax however such changes could involve a disposal which without more might result in a tax liability. The tax regime for reorganisations and reconstructions in TCGA 1992 Chapter II of Part IV is therefore critically important to taxpayers who wish to refine or simplify their current structures.
The tax effect of a reorganisation
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Continuing our series on capital gains relief Robert O'Hare LLM Corporate Tax Group Macfarlanes discusses the nature and application of the regime for reorganisations and reconstructions
Sometimes because it is commercially attractive and occasionally because it is necessary companies restructure their share capital and groups of companies rearrange themselves. Economic ownership is normally unchanged. For UK tax however such changes could involve a disposal which without more might result in a tax liability. The tax regime for reorganisations and reconstructions in TCGA 1992 Chapter II of Part IV is therefore critically important to taxpayers who wish to refine or simplify their current structures.
The tax effect of a reorganisation
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