Tag: corporation tax
Tax Aspects of UK Corporate Demergers
Recorded May 2025 · Episode 11 · 14:57 In this episode I work through the tax treatment of corporate demergers, the process by which a company or group is split into separate parts. I explain the three principal routes — the statutory (exempt) demerger, the capital reduction demerger and the […]
Read MoreUK Corporate Tax Residence and HMRC’s Approach
Recorded March 2025 · Episode 7 · 10:02 In this episode I examine when a company is resident in the United Kingdom for tax purposes and how HMRC approaches the question. I explain the central management and control test that sits alongside the incorporation rule, what the case law tells […]
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