Analysis: company restructures using capital reduction rules

It pays to structure corporate demergers under the relaxed capital reduction rules to take advantage of tax reliefs, says expert Peter Rayney, who unpacks the intricacies of the current tax rules

Company reconstructions and demergers for owner-managed companies seem to be particularly in vogue at the moment. A number of these cases involve the separation of trading and property investment activities carried on by the same company or group.

Typically, the main objective will be to place the property investment and trading activities into separate entities.

This often enables a valuable property investment portfolio to be insulated from ‘trading’ risks and may also bring inheritance tax (IHT) advantages for the shareholders.

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