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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Businesses: mergers and demergers: contents

There are a number of different ways in which two businesses can be merged to form a business carried on by a new partnership and the way this is done will result in different tax consequences. Similar issues arise on the demerger of a partnership business into two (or more) separate businesses.

The way in which any particular merger (or demerger) has been carried out is a question of fact to be determined according to the circumstances of each case.

This section contains the following guidance on business mergers and demergers: