The fiscal implications of company reorganisations

Abstract

In this thesis I shall explore some of the more important taxation implications of common types of restructuring exercises. More specifically, I shall identify the transactions likely to trigger a tax change in the various types of reorganisations, such as, inter alia, share transfers and exchanges, transfers of assets and liabilities, whilst also discussing exemptions and relief given by law to prevent taxation from acting as a disincentive to corporate restructuring exercises. Each type of reorganisation is examined individually with an analysis focused on some of the more salient fiscal implications of that particular reorganisation exercise. Primarily I shall be tackling four types of reorganisations: 1. mergers 2. divisions 3. transfers of assets 4. exchanges of shares