The tax, accounting and company law consequences of restructuring arrangements depend on the precise legal form of the individual transactions which collectively make up those restructuring arrangements. There are a number of different component transaction types that may be combined to form an overall restructuring arrangement. These transaction types include:

(1)transfers by way of sale;

(2)dividends and other distributions not made in the course of a winding up;

(3)dividends and other distributions made in the course of a winding up;

(4)reductions of share capital; and

(5)a compromise or arrangement under Companies Act 2006, Part 26.

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