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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 /Management buyout / D6.437 Management buyout—vendor tax position on a part disposal of the business
Commentary

D6.437 Management buyout—vendor tax position on a part disposal of the business

Corporate tax

Where circumstances are such that it is not desirable for all of the Target company to be included in the buyout, it is possible to either undertake some corporate restructuring or simply do an 'assets' sale for the assets to be bought out.

In a large group of companies a pre-sale reorganisation should not prove too difficult to achieve, as assets could be transferred out of Target to another group company on a tax neutral basis under the various group reliefs see Division D2.3.

However,

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