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Home / Simons-Taxes /Corporate tax /Part D6 Company reconstruction and profit extraction /Division D6.4 Takeovers, mergers, demergers, buyouts and other transfers /Demergers / D6.429 Administration—clearance procedure for a demerger
Commentary

D6.429 Administration—clearance procedure for a demerger


Corporate tax

There are three circumstances in connection with a demerger where application for clearance may be made to HMRC in advance of a proposed transaction:

  1. Ìý

    (a)ÌýÌýÌýÌý a company which is proposing to make a distribution as part of a demerger operation may apply for confirmation that the distribution will be an exempt distribution1;

  2. Ìý

    (b)ÌýÌýÌýÌý a company which is proposing to make a payment which might be a chargeable payment may apply for confirmation that the payment will be made for genuine commercial reasons and that it does not form part of a tax avoidance scheme2;

  3. Ìý

    (c)ÌýÌýÌýÌý a company which becomes or ceases to be connected with

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