Corporate restructuring

You might currently be running a number of companies, but the current structure might not be the most commercial or tax efficient structure. You might find that a corporate restructure can make running your business much more stream-line and bring about more opportunities.

Given the complexities that could come with a corporate restructure and the myriad of tax laws, it is important before any restructure that the appropriate tax advice is sought. Signature Tax can provide you with the tax advice and also propose what the best way to restructure your companies might be. 


Share for share exchanges are implemented in a variety of company reorganisations. A common transaction is where an individual and his business partner might hold all the shares in various companies but wishes to bring all the companies under one holding company.

The benefits of having a group structure can include the following:

  • Group relief losses/gains between the group companies
  • Inter-group transfers of assets will be at no gain/no loss for capital gains tax purposes
  • Risks are ringfenced within each subsidiary
  • Future disposals of certain businesses can be via a share sale and due to the potential availability of certain reliefs for companies disposing of shares, the share sale of a subsidiary could occur at no capital gain chargeable to tax.

Whilst having a group structure can be commercially beneficial, it is important that the share for share exchange is implemented to ensure that the transaction is undertaken in the most tax efficient way. If the correct advice is not sought, then the share for share exchange could be liable to capital gains tax and stamp duty on the transfer of shares.

If you are looking to establish a group structure via a share for share exchange, Signature Tax can assist you with this by providing the necessary tax advice and also implementing the share for share exchange in the most tax efficient way.


It might be the case that you already have a group of companies, but you and your business partner wish to go your separate ways and split the group companies up. The separation of the companies and assets can be achieved by undertaking a demerger.

There are a few different types of demergers; a direct statutory demerger, an indirect statutory demerger or a capital reduction demerger.

Each type of demerger has certain conditions that need to be satisfied and it might be the case that one route would be more suitable than the other.

A demerger is a complex series of transactions and Signature Tax can help with advising on which demerger would suit your scenario, providing the required tax advice and implementing the demerger. 



If you are interested in finding out more, and would like to make a consultation with one of our specialists, please complete the below form, or call us on 0161 850 0648. 

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