Taxation of Company Reorganisations
Taxation of Company Reorganisations

Author: Pete Miller

Publisher: Bloomsbury Publishing

Published: 2020-10-05

Total Pages: 749

ISBN-13: 1526511517

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Taxation of Company Reorganisations, Sixth Edition is an essential reference source for tax advisers which 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. Written by authors with more than fifty years' experience of dealing with clients from small owner-managed businesses to multinational corporate groups, this title includes guidance on the full range of corporate transactions and is applicable to a wide number of organisations. While there is comprehensive coverage of the technical and theoretical meaning of the legislation, the authors have also drawn on their vast practical experience, derived from many years of transaction-based work. This Sixth Edition has been brought fully up to date with recent Finance Acts including FA 2019 and the proposals for FA 2020 that were published in July 2019. It has been reviewed for company and European law and has been updated in relation to the following: - Changes to substantial shareholding exemptions in Finance (No. 2) Act 2017 - Changes to EIS, SEIS and VCT investment schemes in FA 2018 - The introduction of LBTT in Scotland and LTT in Wales - Stamp duty changes proposed for FA 2020 - Enhanced material on the taxation of goodwill and loan relationships on a reorganisation Cases updated since the last edition include: - Gallaher Ltd v Revenue and Customs Commissioners [2019] UKFTT 207 (TC) (on application of s171 TCGA 1992) - Hancock [2019] 1 WLR 3409 (Supreme Court decision) - Trigg [2018] EWCA Civ 17 (Court of Appeal decision)

Taxation of Company Reorganisations
Taxation of Company Reorganisations

Author: Pete Miller

Publisher: Bloomsbury Professional

Published: 2020-11-11

Total Pages: 0

ISBN-13: 9781526511492

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Taxation of Company Reorganisations, Sixth Edition is an essential reference source for tax advisers which 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. Written by authors with more than fifty years' experience of dealing with clients from small owner-managed businesses to multinational corporate groups, this title includes guidance on the full range of corporate transactions and is applicable to a wide number of organisations. While there is comprehensive coverage of the technical and theoretical meaning of the legislation, the authors have also drawn on their vast practical experience, derived from many years of transaction-based work. This Sixth Edition has been brought fully up to date with recent Finance Acts including FA 2019 and the proposals for FA 2020 that were published in July 2019. It has been reviewed for company and European law and has been updated in relation to the following: - Changes to substantial shareholding exemptions in Finance (No. 2) Act 2017 - Changes to EIS, SEIS and VCT investment schemes in FA 2018 - The introduction of LBTT in Scotland and LTT in Wales - Stamp duty changes proposed for FA 2020 - Enhanced material on the taxation of goodwill and loan relationships on a reorganisation Cases updated since the last edition include: - Gallaher Ltd v Revenue and Customs Commissioners [2019] UKFTT 207 (TC) (on application of s171 TCGA 1992) - Hancock [2019] 1 WLR 3409 (Supreme Court decision) - Trigg [2018] EWCA Civ 17 (Court of Appeal decision)

Taxation of Company Reorganisations in Ireland
Taxation of Company Reorganisations in Ireland

Author: Evelyn Ford

Publisher: A&C Black

Published: 2011-08-31

Total Pages: 477

ISBN-13: 184766377X

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This unique new title is the only Irish tax publication which provides an in-depth and comprehensive analysis of the Irish tax issues arising in company reorganisations and reconstructions. The book adopts a practical approach to examining the principal considerations arising from the types of reorganisations typically undertaken by Irish companies. The text includes a number of worked examples, case studies and tax planning points relevant to this complex area. Providing a comprehensive analysis of relevance to tax practitioners in both large and small tax firms, it considers the practical application of tax law in key areas, including:- Restructurings in the context of incorporation - Group reorganisations/reconstructions - Restructurings for sale - Share capital reorganisations - Earn outs and long term incentive schemes - Anti-avoidance - An introduction to relevant company law and accounting issues is also included. EURO: 175

Fit for Growth
Fit for Growth

Author: Vinay Couto

Publisher: John Wiley & Sons

Published: 2017-01-10

Total Pages: 296

ISBN-13: 1119268532

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A practical approach to business transformation Fit for Growth* is a unique approach to business transformation that explicitly connects growth strategy with cost management and organization restructuring. Drawing on 70-plus years of strategy consulting experience and in-depth research, the experts at PwC’s Strategy& lay out a winning framework that helps CEOs and senior executives transform their organizations for sustainable, profitable growth. This approach gives structure to strategy while promoting lasting change. Examples from Strategy&’s hundreds of clients illustrate successful transformation on the ground, and illuminate how senior and middle managers are able to take ownership and even thrive during difficult periods of transition. Throughout the Fit for Growth process, the focus is on maintaining consistent high-value performance while enabling fundamental change. Strategy& has helped major clients around the globe achieve significant and sustained results with its research-backed approach to restructuring and cost reduction. This book provides practical guidance for leveraging that expertise to make the choices that allow companies to: Achieve growth while reducing costs Manage transformation and transition productively Create lasting competitive advantage Deliver reliable, high-value performance Sustainable success is founded on efficiency and high performance. Companies are always looking to do more with less, but their efforts often work against them in the long run. Total business transformation requires total buy-in, and it entails a series of decisions that must not be made lightly. The Fit for Growth approach provides a clear strategy and practical framework for growth-oriented change, with expert guidance on getting it right. *Fit for Growth is a registered service mark of PwC Strategy& Inc. in the United States

Corporate Tax Law
Corporate Tax Law

Author: Peter Harris

Publisher: Cambridge University Press

Published: 2013-03-07

Total Pages: 651

ISBN-13: 110731142X

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Many corporate tax systems lack structure. Focusing on structural defects and how they are addressed in practice, this comprehensive and comparative analysis of corporate tax systems uses a conceptual framework to illustrate and analyse the many difficult issues corporations pose. This framework is enhanced by the examination of a large body of legal rules and practical considerations which demonstrate how corporate tax systems work in practice. While adopting a broad comparative approach, the analysis also drills down into the detail of influential corporate tax systems in order to illustrate the major issues they face and the options available to them.

European Union Corporate Tax Law
European Union Corporate Tax Law

Author: Christiana HJI Panayi

Publisher: Cambridge University Press

Published: 2013-05-09

Total Pages: 413

ISBN-13: 1107354986

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How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This unique study traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies and permanent establishments. Existing legislation, soft-law and the case-law of the Court of Justice are examined. The proposed CCCTB Directive and its potential application through enhanced co-operation are also considered. In addition to the tax issues pertaining to direct investment, the author examines the taxation of passive investment income, corporate reorganisations, exit taxes and the restrictive effect of domestic anti-abuse regimes. By doing so, the convergences and divergences arising from the interplay of EU corporate tax law and international tax law, especially the OECD model, are uncovered and highlighted.

Luxembourg in International Tax Planning
Luxembourg in International Tax Planning

Author: Philip J. Warner

Publisher: IBFD

Published: 2004

Total Pages: 588

ISBN-13: 9076078610

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Study, divided into five parts: a short introduction to Luxembourg as a country and financial centre; calculation of profits taxes and other taxes to which a fully-taxable resident business is subject; the fully-taxable "special purposes vehicles" available in Luxembourg including banking and reinsurance; tax exempt vehicles, the 1929 holding company and investment funds; and corporate reorganizations and examples of how Luxembourg could be used in international tax planning