Insolvency proceedings - how to guide your clients through CVAs, Receivership, Administration and Liquidation

This session covers each of the types of proceedings (CVAs, receivership, administration and liquidation), explaining how they work, before covering the tax implications for each of them:

• The impact for the group (as a result of the company losing beneficial ownership of its subsidiaries)
  • Group relief from corporation tax
  • Corporation tax on chargeable gains on transfers of assets within the group and potential exit charges
  • SDLT on transfers of property within the group and potential claw-backs of group relief
  • Stamp duty on transfers of shares within the group
  • Intra-group transfers of loans and the loan relationship rules
  • VAT on intra-group transactions (if there is a VAT group)
• The impact for the shareholders of the company in insolvency
  • Tax treatment of a distribution on winding-up; income or capital?
  • Distributions in specie, including land (CGT, SDLT and VAT implications)
  • Business Asset Disposal Relief from CGT
  • Relief for worthless shares (CGT negligible value claim)
• Cessation of trade and transfer of trade
  • Capital allowances (disposal event)
  • Terminal loss relief
  • Carry-forward of losses on transfer of the trade

The session will also briefly cover the possible tax implications of a restructuring done under a CVA proposal (in particular, hiving-down businesses or rescheduling/releasing debt).