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Home / Simons-Taxes /Corporate tax /Part D6 Company reconstruction and profit extraction /Division D6.5 International reorganisations /Takeovers and mergers—international aspects / D6.535 Dual-headed merger structures
Commentary

D6.535 Dual-headed merger structures

Corporate tax

A dual-headed structure allows two companies to combine their operations and yet retain a degree of separation. This is achieved by retaining the merging companies as separate legal entities but putting in place arrangements to ensure that the group, as a whole, operates as if it were a single enterprise. This achieves certain political, commercial and tax advantages that may not be obtained with a conventional merger.

Dual headed structures usually consist of the two merging companies ('top-tier companies')

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