Reconstructions involving transfer of business

Copyright © 2024 LexisNexis
Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Reconstructions involving transfer of business

Copyright © 2024 LexisNexis
Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

The ‘paper for paper’ rules relating to share for share exchanges (discussed in the Share for share exchange guidance note) are extended to deal with reconstructions. Relief is available to shareholders where there is a reconstruction involving the issue of shares, and when there is a reconstruction involving the transfer of a business. These are considered in more detail below.

Reconstructions involving share issues

Where there is a reconstruction involving the issue of shares and it:

  1. •

    involves an arrangement between a company (Company A) and either:

    1. ◦

      the persons holding shares in or debentures of the company

    2. ◦

      where there are different classes of shares in or debentures of the company, the persons holding any class of those shares or debentures

  3. •

    is entered into for the purposes of, or in connection with,

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  • 04 Mar 2024 12:02

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