The exempt distribution provisions for dividend demergers are studded with strict tests and conditions. Most derive from the original version of the relief, which was introduced in 1980 when ACT was still in point; they now appear to be outdated and/or no longer relevant. It seems counterintuitive for the availability of specific demerger relief to be so constrained by rules designed with the ACT regime in mind, given that many demergers can generally still be implemented in a tax-efficient manner by structuring them as a scheme of reconstruction.
.tmb-editorspic.jpg?sfvrsn=df04ab27_1)
