Lisa Stevenson (Parisi Tax) answers a tax query a demerger involving the return of capital
Jeanette Zaman and Emma Game (Slaughter and May) consider whether the conditions for demergers to qualify as exempt distributions are in need of an overhaul
Jeff Webber answers a query on whether a loan could be caught as a ‘chargeable payment’ under CTA 2010 s 1088.
Bradley Phillips and Perminder Gainda explain the tax implications of the different types of demerger structures that UK companies typically adopt to split their activities into two or more separate companies, along with a worked example
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