Chris Harrison and Ben Brown examine the key corporation tax deductibility and VAT recovery issues on M&A deals.
Corporation taxThere are three primary distinctions which need to be drawn when analysing the corporation tax treatment of transaction costs in the context of an M&A deal. The first is whether or not those costs relate to financing (more specifically whether the expense is incurred under or for the purposes of a loan relationship) or one of certain other accounts-based tax regimes. The second and third which become relevant where the costs do not fall into one of those regimes are whether the costs have a capital or revenue nature and whether the costs are trading...
