Pete Miller: Taxation of Company Reorganisations, Kartoniert / Broschiert

Klappentext

Now in its 7th Edition , Miller, Hardy and Ismail on Company Reorganisations (previously Taxation of Company Reorganisations ), is an essential reference source for tax advisers that covers the basic rules of corporation tax and capital gains, reorganisations, share exchanges and other deemed reorganisations, reconstructions, mergers, demergers and branch incorporations, as well as cross-border transactions.

A variety of topics are discussed, from the reduction of capital rules, and interaction with substantial shareholding exemption, to qualifying corporate bonds (QCBs), reconstruction reliefs, and UK and cross-border mergers. The new edition brings the commentary up-to-date with recent Finance Acts including new provisions relating to share exchanges involving non-UK incorporated close companies introduced in Finance (No. 2) Act 2023; and relevant new guidance from HMRC. There is also a new chapter on the multinational top-up tax and domestic top-up tax provisions as these apply to reorganisations.

A number of important new cases are also analysed, including the following:

• Euromoney Institutional Investor PLC (FT) : Anti-avoidance on exchange of shares
• Gallaher (various including UT and CJEU) : intra-group transactions and EU law
• Kavanagh (FT): Holding shares on trust
• Blackrock (UTT) , Oxford Instruments (FTT), and Kwik Fit Group Ltd (UT) : unallowable purpose test
• Altrad Services (UT) : disclosed avoidance scheme
• M Group Holdings (FTT): substantial shareholding exemptions.