Reorganisations: the nuts and bolts

Once the starting point and end point of a corporate reorganisation have been decided the next question is: how do you get from here to there? There are various types of transactions that may be involved in the implementation phase and this article looks at some common ones:

• distributions in cash or in specie;
• repayments of capital;
• liquidations; and
• intra-group transfers of assets.

These transactions engage a number of different sets of tax rules and issues: the taxation of dividends and other distributions the capital distributions rules ...