Description

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This title is an essential reference source for tax advisers who need to offer clear and concise guidance clients who are looking to restructure their business. Drawing on the years of transactional experience gathered by the principal authors, Pete Miller and George Hardy, it includes guidance to a variety of topics from the reduction of capital rules, to using them for tax structuring, to EU cross-border transactions.The guidance is applicable to a wide range of organisations; from small owner managed businesses up to the largest public companies. The basic principles behind the relevant legislation are laid out, including relevant EU legislation such as the Mergers Directive and the Cross Border Mergers Directive. The commentary then looks at the various options open to companies, from reorganising to branch incorporation. The rules are analysed with the available reliefs laid out. The new edition is updated in relation to the following: - Changes to the substantial shareholding exemptions in Finance Act No 2017 - Changes to EIS, SEIS, and VCT investment schemes in FA 2018- The Stamp Taxes chapter will be updated to take account of the introduction of LBTT in Scotland and LTT in Wales

About the Author

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Pete Miller, CTA (Fellow), Partner, The Miller PartnershipPete Miller has nearly 25 years' experience in tax, covering all aspects of business and corporation tax issues. Pete founded The Miller Partnership in 2011 to offer expert advice on all business tax issues to other advisers, particularly lawyers and accountants. Specialist areas include reorganisations and reconstructions, the substantial shareholdings exemption, transactions in securities, HMRC clearances, disguised remuneration, taxation of intangible assets and the new patent box legislation.George Hardy is a Financial Services Tax Partner of Ernst & Young LLP and head of their Financial Services Mergers and Acquisition Tax Practice. He is a contributor to many publications.Fehzaan Ismail is a Senior Manager in EY's International Tax and Transaction Services team and advises clients in the Financial Services sectors. His specialist areas include chargeable gains (including reorganisations), loan relationships, foreign PEs, hybrids and other mismatches and the taxation of intangible assets. Fehzaan has also been heavily involved in the delivery and thought leadership on the tax issues arising on Brexit restructuring transactions.