Reorganisations / reconstructions ― IFAs

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

Reliefs for reorganisations and reconstructions are available in respect of intangible fixed assets with rules that effectively provide the same reliefs which are available for assets within the scope of corporation tax on capital gains.

Reconstructions / demergers

Any intangible fixed assets transferred as part of a company reconstruction, including a demerger, involving the transfer of a business or part of a business are treated as transferred on a tax-neutral basis provided certain conditions are met. This operates in the same way as for an intra-group transfer. The rules on intra-group transfers take precedence if the reconstruction involves a transfer within a group.

Conditions

The conditions for the tax-neutral transfer are that:

•
there is a scheme of reconstruction involving the transfer of the whole or part of the business from one company to another (see the Reconstructions guidance note)
•
the transferor must receive no consideration other than the assumption of the business’ liabilities by the transferee
•
the intangible fixed asset must be a chargeable fixed asset (ie within the corporate intangible tax regime)

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