VtaxP: Re-organisation toolkits

1. A trading company has two trading activities. its owners wish to split each trade into different companies.

They either wish to split the two trades between the same owners or they want to divide the trades each to the existing owners

Why?

• Potential sale of one trade
• Separation/fallout of business partners

Toolkit: VtaxP1: Trades Demerger Toolkit

2. A profitable trading company has acquired investment property, assets or investment business. Its owners wish to separate out the trade and investment activities.

Why?

• Potential sale of trade or investment business or investment asset
• To preserve CGT Entrepreneurs Relief (ER) or IHT Business property Relief (BPR).

Toolkit: VtaxP2: Investment Property Removal Tookit

3. Trading company with investment subsidiary

• Break up group and create two stand alone companies

Why?

• Potential sale of trade, trading company or investment business
• To preserve CGT ER or BPR

See VtaxP3: Tradeco demerger of investment subsidiary

4. Investment company with trading subsidiary:

• Break up group and create two stand alone companies

Why?

• Potential sale of trading company or investment business
• To preserve CGT ER or BPR

See VtaxP4: Investco demerger of trading subsidiary

5. Management buyout

• Form new holding company to buy out existing shareholders

For?

• Buyout by existing shareholders or by a combination of existing shareholders and employees 

Why?

• Borrow against assets of new subsidiary
• Share for share exchange for existing shareholders

See VtaxP5: Management buyout: via new holdco

6. Purchase of own shares

• A purchase, by a company of its own shares from a retiring shareholder.

For?

• Buyout retiring or dissenting shareholder 

Why?

• Use company funds to buy shares
• Borrow against company assets to buy shares

See VtaxP6: POS: buyout retiring shareholder

7. Creating a group

• Adding a new holding company, or
• Creating new subsidiaries

Why?

• To separate new or different activities
• To create a holding company for a share scheme or investment relief
• Asset protection

See VtaxP7: Creating a group