BIM72401 - Partnerships: Mergers and Demergers: General

There are a number of different ways in which two businesses can be merged and the way this is done will result in different tax consequences. Similar issues arise at 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.

For examples of how the provisions relating to mergers are to be applied see BIM72430.