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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 / D6.441 Administration—clearance applications for a management buyout

D6.441 Administration—clearance applications for a management buyout

Corporate tax

It is likely to be the vendor rather than the purchaser in an MBO transaction who will want to apply to HMRC for advance clearances or assurances. However, whilst clearance applications can be prepared and submitted by the vendor, the purchaser should be given a right

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I4.142A Liabilities which are not discharged out of the estate

I3.367 Fall in value relief—changes in interests in land

C2.1020 Employment-related securities options and capital gains

C1.213 Liability to tax on chargeable gains—trustees in bankruptcy

B5.820 Charity's profits of trade—general liability to income tax

C2.902 Wasting assets—wasting of allowable expenditure

B2.319 Duality of purpose—apportionment of the expenditure

I7.120A BPR and excepted assets

C1.511 Use of Mansworth v Jelley losses

D3.410 Benefits provided by close companies to participators

B3.1006 The relevant interest

E6.324H Nominated income and gains and the ordering rules

D1.1061 Substantial shareholding exemption—interaction with other reliefs

B3.306 Meaning of plant and machinery

B2.472 Tax and tax-related expenditure

D6.330 Special situations involving a transfer of trade with common ownership—business of leasing plant or machinery

B2.202 Capital receipts

E1.416 Dividends from non-UK resident companies—general

D4.412 CFCs—excluded territories exemption

I5.1304 Beneficiary with contingent interest