Rollover relief for group companies meaning

Why do companies have reorganisations? Groups of companies carry out reorganisations for numerous and varied reasons. These steps will frequently have implications for existing share plans and other employee equity arrangements. In some instances, the consequences are commercial in nature. Examples include: the reorganisation prompting early vesting, exercise and/or lapse of awards because the relevant provisions in the share plan rules on a change in control of the parent company, or on the participant’s employment ending, have been engaged; and a requirement for awards over shares in the current parent to be swapped for awards over shares in a newly formed parent company. In certain situations, if the right steps are not taken within a defined period, valuable tax advantages may ultimately be lost entirely. Common types of reorganisation The most frequent forms of reorganisation include the following: placing a new group holding or parent entity above an existing company or group, often to enable an initial...

Roll-over relief under the corporate intangible assets regime in Part 8 of Corporation Tax Act 2009 (CTA 2009) This Practice Note considers the roll-over relief available under the corporate intangible assets regime in Part 8 of the Corporation Tax Act 2009 (CTA 2009). Relief is not automatic; it must be claimed. It applies where a company realises an IFA (the old asset) and then incurs expenditure to acquire another IFA (the new asset). The rules can likewise apply if the new asset is obtained by another company within the same IFA group. In broad terms, the regime postpones all or part of the taxable credit that would arise on the realisation of the old asset. That deferred credit is brought back into charge when the new asset is realised (unless roll-over relief is also claimed on that later event). Crucially, where debits have been taken into account for the old asset—such as tax relief for amortisation—the deferral will not cover the entire amount of the realisation credit. An analogous...