Hive Downs & Taxes on Business Disposals - Hive Up or Hive Down?

Introduction

This virtual classroom session will explore the taxes which apply on the disposal of a business and how these are dealt with in a business purchase agreement.

Aimed at tax professionals and corporate lawyers, it will provide a working example of a hive down alternative for disposing of business assets and high-level demerger alternatives to a hive down within a group.

What You Will Learn

This live and interactive session will cover the following:

Taxes on Business Disposals

• Direct taxes on business disposals
• Capital gains assets
• Loan relationships
• Intangible fixed assets
• Capital Allowances
• Stock/WIP
• VAT - TOGC rules
• Stamp taxes
• Documenting the disposal, what should the asset purchase agreement say on taxes?
• International issues, issues arising on multi-jurisdictional business transfers

Hive Downs

• Group transfers and de-grouping rules for:
• Capital gains assets
• Loan relationships
• Intangible fixed assets
• Capital allowances
• Stock/WIP
• Loss carry forwards and tax assets - anti-avoidance rules
• Substantial shareholding exemption
• VAT - TOGC/VAT grouping
• Stamp taxes and de-grouping
• International issues - a high level look at structuring where the business is based in a number of jurisdictions

High Level Demerger Alternatives

• Forms of merger - liquidation reconstruction v return of capital v statutory demerger
• Obtaining reliefs: s136 TCGA/s139 TCGA
• Avoiding a distribution
• Transactions in securities rules
• VAT

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.