Course outline:
Group companies can be involved in many types of transaction, from a (relatively) straightforward sale of a company to a third party, through to more complex deals such as hive-downs/hive-ups and demergers.
Getting the important tax consequences of these deals correct hinges on a good understanding of the corporation tax rules involving groups. These rules will be covered thoroughly, particularly where they have undergone major reform in the recent past.
The course will include practical examples, such as merging two trades into one company or demerging a business into two separately owned companies.
Although emphasising the corporation tax areas, the course will also cover relevant personal tax points for shareholders, along with practical issues, such as obtaining clearance on anti-avoidance legislation from HMRC.
CPD Hours: 3
The contents of courses predating 2026 may vary.
Course details:
The topics covered will include:
- Company losses
- Group relief
- Group structures
- Planning
- Capital gains
- Group structures
- De-grouping charges
- Planning opportunities
- Substantial shareholder exemption
- Sale of company
- Transfer of trade
- To third parties
- Within a group
- Hive-downs and hive-ups
- Demergers
- Statutory and insolvent demergers (overview only)
- Capital reduction demergers, including a case study
- The problems when using share buy-backs in succession planning, including a case study
- Practical issues, including
- ‘Transactions in securities’ anti-avoidance rules
- Obtaining clearances
- Warranties and indemnities
- Key personal tax areas for shareholders, including protecting business asset disposal relief
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