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Down and out?
Amid falling profits and asset values many companies will find themselves where they do not want to be – whether with a lack of reserves in administration or in liquidation. Putting aside the limited scope for tax planning in these scenarios some issues are worth considering particularly the tax consequences of even the simplest group transactions. These include the transfer of assets around a group the waiver of debt and the use of tax losses.
To illustrate these issues we will consider the position of the Piste Group.
Piste Holdings Limited is the parent of the following companies:
- Green Limited owns the business property and has no distributable reserves;
- Blue Limited operates a winter sports business and is in administration; and
- Red Limited is developing an online app and also has a trading subsidiary Black Limited ...
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