Back to basics: Company demergers

Groups contemplating a demerger are not short of options when it comes to seeking tax neutrality. But while it is generally possible to effect a demerger without incurring tax charges at either the shareholder or corporate level, getting there can be far from straightforward. Taxpayers must satisfy stringent conditions to benefit from the – admittedly generous – statutory demerger regime. And demerging by way of liquidation or capital reduction, although tried and tested, is not specifically catered for in tax law, leaving taxpayers to rely on generic restructuring reliefs.