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Corporate Restructuring and demergers

Temple Tax has some of the leading practitioners advising on corporate restructuring.  Members of Chambers include the current authors of the foremost commentary in this area: Bramwell on Taxation of Companies and Company Reconstructions published by Sweet and Maxwell.  Members advise large corporates and SME’s on all aspect of restructuring including all direct taxes, stamp duty, SDLT and claims under Double Tax Treaties.  Members have decades of experience of drafting Clearance Applications and are expert not only on the technical requirements of the reliefs but also on the presentation of applications so as to maximise the changes of successful clearance being granted.  Where a clearance is refused, members are experienced in challenging refusals before the Tribunals and have been involved in some on the leading recent cases on challenging section 136 and section 139 refusals.


Matters on which members have recently advised include:


  • Reduction of capital reconstructions and partitions.
  • Liquidation reorganisations and re-basing assets.
  • SDLT and partitions.
  • Stamp duty issues in the light of section 77A FA 1986 and the FA 2020 anti-shareswamping provisions
  • Share cancellation schemes.
  • Tidying up groups prior to a demerger.
  • Statutory demergers.
  • Transactions in Securities provisions (section 684) and returns of capital, reorganisations ahead of sale, retained interests following a buy-out, successions and the scope of the Fundamental Change of Ownership safe haven (section 686).
  • Partitioning jointly held companies.


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