Send us a text In this episode of The UK Tax Podcast, Chartered Tax Adviser John Kavanagh explains the tax treatment of corporate demergers under UK law, focusing on the three principal routes: statutory demergers, capital reduction demergers, and reconstructions by liquidation. Designed for non-specialist advisers, the episode sets out the conditions for each type of demerger, identifies key tax and legal risks, and discusses the availability of reliefs from income tax, CGT, SDLT and VAT. Th...
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Send us a text In this episode of The UK Tax Podcast, Chartered Tax Adviser John Kavanagh explains the tax treatment of corporate demergers under UK law, focusing on the three principal routes: statutory demergers, capital reduction demergers, and reconstructions by liquidation. Designed for non-specialist advisers, the episode sets out the conditions for each type of demerger, identifies key tax and legal risks, and discusses the availability of reliefs from income tax, CGT, SDLT and VAT. Th...
Tax Risks of Liquidation Distributions – Navigating the TAAR
UK Tax Podcast
7 minutes
8 months ago
Tax Risks of Liquidation Distributions – Navigating the TAAR
In this episode of The UK Tax Podcast, John Kavanagh, Chartered Tax Adviser, examines the risks of distributions in a liquidation being taxed as income rather than capital under the Targeted Anti-Avoidance Rule (TAAR). With no binding case law and limited guidance from HMRC, this is a highly uncertain area, particularly where individuals resume similar business activities after a winding up. John explains how the TAAR operates, the importance of Conditions C and D, and why securing Business A...
UK Tax Podcast
Send us a text In this episode of The UK Tax Podcast, Chartered Tax Adviser John Kavanagh explains the tax treatment of corporate demergers under UK law, focusing on the three principal routes: statutory demergers, capital reduction demergers, and reconstructions by liquidation. Designed for non-specialist advisers, the episode sets out the conditions for each type of demerger, identifies key tax and legal risks, and discusses the availability of reliefs from income tax, CGT, SDLT and VAT. Th...
