Published on 14 Oct 10
by NATIONAL DIVISION, THE TAX INSTITUTE
This paper covers:
- interaction of the demerger rules with the tax consolidation regime
- no demerger relief for CGT event L5
- head company as a "demerging entity"?
- cost setting anomoly
- CGT straddle contracts - intra-group dealings
- straddle contract between group members
- straddle contract over an intra-group interest.
Richard has been a Director of Greenwoods & Freehills since 1998. Richard advises on a wide range of corporate tax matters. He has extensive experience in advising listed companies and stapled groups on mergers and acquisitions, demergers, company restructures and capital management transactions. Richard also advises listed groups on employee share and rights plans.
- Current at
06 February 2014