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...
Send us a text In this episode of The UK Tax Podcast, John Kavanagh examines the rules regarding UK corporate tax residenceand the approach taken by HMRC. He explains the UK’s central management and control test, how HMRC has challenged offshore structures, and the role of double tax treaties in resolving residence disputes. The episode also explores the growing use of the mutual agreement procedure in modern treaties and touches on the relevance of permanent establishment rules for non-resid...
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...
