Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Footy funding

26 February 2008
Issue: 4147 / Categories: Forum & Feedback
Tax-efficient company restructuring

I was recently asked how the acquisition of a company could be effectively self-financing (as the Manchester United acquisition allegedly was) and in a tax-efficient manner.

I wondered whether the solution might be to acquire the target trading company via a holding company.

The holding company's loan for the acquisition would be funded via dividends from the target trading company.

The loan interest payments by the holding company would create a loss (or a non-trading loan relationship deficit) which could then be surrendered to the target trading company.

The result would be that the trading target had funded its own acquisition and received tax relief on the interest element.

Do readers consider that this strategy works or is there a better more tax-efficient way? Does the location of the company (in the UK or abroad) make any...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

back to top icon