Section 127 of the Insolvency Act 1986 (“IA 1986”) provides that any disposition of the company’s property made after the commencement of the winding up is void. It is estimated that Harry Ltd's shares were worth about £500,000 at 31 March 1982. in accordance with the company’s constitution and only exercising that power for their intended purpose; To avoid conflicts of interest (s175) 6. The Revenue has indicated that temporary/short-term investment of surplus funds in equities and cash deposit accounts should not prejudice the company's trading status provided such amounts are required for future business purposes, typically where they are earmarked for anticipated working capital or capital investment requirements. Since 1 April 2002, capital gains realised by UK groups on the sale of their subsidiaries, etc, are exempt from tax provided the detailed conditions laid down in Sch 7AC of the Taxation of Chargeable Gains Act (TCGA) 1992 are satisfied. Although the transaction potentially qualifies for share exchange relief under s135, TCGA 1992, para 4(1)(b) deems the transaction to be a disposal for SSE purposes. 18 of 2015 3 NO. This is … S171: requires the directors to act within their powers, i.e. Any creditor may object to the release of the Liquidator by giving notice in writing to the Liquidator before the end of the Prescribed Period. This means that a holding company may still qualify for SSE relief if it sells its only trading subsidiary and reinvests the sale proceeds in buying a 51% stake in another trading company. gain/no loss’ basis under s171 (the intra-group asset transfer rule). The 'trading company' definition is based on the one used for CGT business asset taper relief purposes, where the Revenue applies a 20% de minimis limit for non-trading activities. Insolvency Act 1986 (1986 C 45) Town And Country Planning Act 1990 (1990 C 8) Consumer Rights Act 2015 (2015 C 15) Police And Criminal Evidence Act 1984 (1984 C 60) Sign-in Help. The requirement for the investing company to be a trading company (or member of a trading group) immediately after the disposal is likely to deny relief where, for example, a holding company sells its only (trading) subsidiary company. This new section provides that, where the assets of the It must also be a sole trading company or trading group member immediately after the disposal (para 18). These are the duties which directors of a company owe towards the company. In the two-year period before the sale of the substantial shareholding, the investing company must have been a trading company or trading group member for at least a 12-month period. For example, making loans or leasing property to another 51% group member is not regarded as an investment/non-trading activity. Also it is important that the directors consider and keep in mind the decisions made by the shareholders while using their powers [ 13 ] . Insolvency No. In such cases, the acquisition must be made 'as soon as reasonably practicable in the circumstances'. The Revenue has acknowledged that this may not satisfy the trading company requirement unless the holding company planned to acquire another trade or a significant equity interest in a trading company or group within the near future (see below). Hence, if a subsequent sale of the new shares did not attract the SSE, the gain on the old shares would be taxed as part of the overall gain.). The Liquidator will vacate office under s171 of the Insolvency Act 1986 on delivering to the Registrar of Companies the final account and notice saying whether any creditor has objected to release. Previously, UK-based groups usually suffered a tax charge when they sold off their subsidiary companies. Furthermore, the investing company must also be a sole trading company or trading group member immediately after the sale (para 18). For these purposes, a trading company is a company carrying on trading activities that do not to any substantial extent include non-trading activities (para 20). • The entire share capital of Harry Ltd clearly represents a 'substantial shareholding' held throughout the same relevant period. To act within powers (s171) 2. Part 1 Interpretation and scope. Most types of joint venture investments should benefit from the transparency rule in para 23. It is clearly important that any non-trading activities carried on by the investee company or group fall below the de minimis 20% threshold, otherwise the disposal would not be protected by the SSE and thus would potentially be exposed to a tax charge. A very helpful extension to the meaning of 'trading activities' embraces activities carried on with a view to: • acquiring or starting to carry on a trade, or. The corporate structure of the Hogwarts Group shown below (indicating the relevant percentage of ordinary share capital and voting rights held for each holding) has remained the same for many years. The rules governing directors come from a variety of sources. He recently received the 'Tax Writer of the Year' award at the Butterworths Tolleys Tax Awards 2002. The sale of Harry Ltd is likely to take place on 31 December 2002 and legal heads of agreement for a share sale were finalised some weeks ago. ... new s176A into the Insolvency Act 1986. However, where a corporate reconstruction falls outside the s139, TCGA 1992 provisions, the transfer of the subsidiary may be relieved under the SSE. This relief can only be used if the investing company controls the investee company or a fellow group member (para 3). The investing company satisfies the substantial shareholding requirement provided it is beneficially entitled to at least 10% of the: • investee company's ordinary share capital, • profits available for distribution to the investee company's equity holders (see Sch 18, ICTA 1988), and. However, a subsequent degrouping charge would be triggered when the liquidator subsequently distributes the shares in the subsidiary company as part of the s110 Insolvency Act 1986 arrangement. 20% of Quidditch Ltd is owned by Nimbus Two Thousand plc. 2. This provision applies where the transaction has been solely or mainly motivated by the SSE and produces a gain entirely or almost entirely relating to untaxed profits. The legislative requirement to take all the activities of the group together ensures that any intra-group transactions are effectively ignored. PART II —INSOLVENCY PRACTITIONERS 4. The SSE is also dependent on the investing company having a substantial shareholding in the relevant investee company throughout a 12-month period within the two years before the shares are disposed of (para 7). The forgiven debt may be excluded as income under the "insolvency" exclusion. Insolvency Act, 2018. There are rules contained within case law and within specific legislation (such as employment, health and safety and insolvency legislation) but the Companies Act 2006 (“CA 2006”) sets out a director’s duties.. For example, there is a risk that the valuable SSE could be denied where a company has amassed substantial cash balances that do not appear to be necessary for current or future trading purposes. Provided the company or group holds at least 10% of a trading JVC's ordinary shares, it is treated as carrying on an appropriate part of the JVC's trade. 3.4 A reasoned opinion of likely legal implications, including remedies and defences, where ... directors: s171 CA 2006 (Duty to act within powers). Similarly, the corporate gains reconstruction provisions of s139, TCGA 1992 also override the SSE. Where shares are transferred to another 75% group company, the normal s171, TCGA 1992 no gain/no loss rule takes precedence and the SSE does not apply (para 6). Duty to act for Proper Purposes: The statutory duties owed by a company director are set out in the CA 2006 s171 – 176. On the other hand, if the disposal satisfies all the SSE conditions but produces a capital loss, that loss no longer counts as an allowable loss for reducing the company's/group's capital gains (s16(2) TCGA 1992). (The SSE is beneficial, since otherwise under s127, TCGA 1992 there would have been deemed to be no disposal for tax purposes, with the 'new' consideration shares having been acquired at the same time and cost as the old shares. 3. • assets that would be distributed on a winding up of the investee company. A degrouping charge arises where a company leaves a chargeable gains group owning a chargeable asset which it acquired within the previous six years from another company in the group, usually triggering any loss or gain that was deferred on an intra-group transfer (section 179, Taxation of Chargeable Gains Act 1992) (TCGA). This would typically arise where the investing company sells its subsidiary ( to a non-group company) in exchange for shares. Insolvency Act (IA)1986. Leviosa Spa, an Italian resident company, holds the remaining 85% of Broomstick Ltd's ordinary share capital. All Rights Reserved, Amended by Financial Matters Amendment Act 18 of 2019, Amended by Financial Sector Regulation Act 9 of 2017, Amended by National Credit Amendment Act 19 of 2014, Amended by Financial Markets Act 19 of 2012, Amended by National Credit Act 34 of 2005, Amended by Securities Services Act 36 of 2004, Amended by Judicial Matters Second Amendment Act 55 of 2003, Amended by Judicial Matters Amendment Act 16 of 2003, Amended by Insolvency Second Amendment Act 69 of 2002, Amended by Insolvency Amendment Act 33 of 2002, Amended by Judicial Matters Amendment Act 42 of 2001, Amended by Administration of Estates Laws Interim Rationalisation Act 20 of 2001, Amended by Cross-Border Insolvency Act 42 of 2000, Amended by Judicial Matters Second Amendment Act 122 of 1998, Amended by Judicial Matters Amendment Act 34 of 1998, Amended by Judicial Matters Amendment Act 104 of 1996, Amended by General Law Amendment Act 49 of 1996, Amended by Insolvency Amendment Act 32 of 1995, Amended by General Law Fifth Amendment Act 157 of 1993, Amended by General Law Third Amendment Act 129 of 1993, Amended by Insolvency Amendment Act 122 of 1993, Amended by Security by Means of Movable Property Act 57 of 1993, Amended by General Law Amendment Act 139 of 1992, Amended by Financial Institutions Amendment Act 54 of 1991, Amended by Insolvency Amendment Act 6 of 1991, Amended by Insolvency Amendment Act 89 of 1989, Amended by Insolvency Amendment Act 27 of 1987, Amended by Transfer of Powers and Duties of the State President Act 97 of 1986, Amended by Insolvency Amendment Act 84 of 1984, Amended by Insolvency Amendment Act 101 of 1983, Amended by Insolvency Amendment Act 78 of 1980, Amended by General Law Amendment Act 29 of 1974, Amended by General Law Amendment Act 62 of 1973, Amended by Insolvency Amendment Act 6 of 1972, Amended by Insolvency Amendment Act 99 of 1965, Amended by Income Tax Amendment Act 6 of 1963, Amended by General Law Amendment Act 50 of 1956, Amended by General Law Amendment Act 32 of 1952, Amended by Merchant Shipping Act 57 of 1951, Amended by Insolvency Law Amendment Act 16 of 1943. to consolidate and amend the law relating to insolvent persons and to their estates. throughout the qualifying period, which runs from the start of the relevant 12-month substantial shareholding period until the disposal date, as well as immediately after the disposal (para 19). 5.5 Application of understanding to a complex scenario. Care should be taken on earn-out transactions since the capital gains arising on earn-out payments would not qualify for the SSE. My experience has been that the Revenue has tended to argue that a company does not qualify if it has substantial non-trading assets, even though all the other measures listed above relate completely to trading activities. Directors owe various duties to the company, which are set out in the Companies Act 2006 and are as follows: 1. Without this special rule, a minority shareholding in a joint venture company (JVC) would be regarded as an investment activity, thus potentially prejudicing the shareholder's trading status. To provide for the administration of insolvent and assigned estates and the consolidation of Insolvency legislation in Zimbabwe; to repeal the Insolvency Act [Chapter 6:04] and to provide for matters connected with or incidental to the foregoing. The sale of the entire share capital of Harry Ltd should qualify for the SSE. The investee company in which the shares are held must be: • a holding company of a trading group (or trading subgroup). Here, the sale of the subsidiary is tax-free under the SSE, which trumps the share exchange relief in s135, TCGA 1992. Clearly the SSE provides a valuable relief in this case as it avoids an immediate tax liability of around £647,000 on the sale, calculated as follows: As the SSE applies to the entire £4m sale consideration, including the part satisfied by the shares issued by Wizard plc, Hogwarts (Holdings) Ltd will acquire the Wizard plc shares at a capital gains base cost of £1m (rather than at a pro rata proportion of its base cost in Harry Ltd's shares). To exercise independent judgment (s173) 4. Section 2: Insolvency Act 2006 brought into force, on 3 December 2007, by clause 2 of the Insolvency Act 2006 Commencement Order 2007 (SR 2007/332). If you’re already a subscriber, log in to access the CPD Tracker to check your points to date and export the data from your personal records. 3) The company in which the shares are held (ie, the investee company) must be a qualifying trading company or qualifying holding company of a trading group throughout the qualifying period defined in (1) above and immediately after the disposal too (para 19). This put them at a major competitive disadvantage when compared to the tax exemptions granted by most other jurisdictions. (This is because the actual payments derive from the earn-out right as opposed to the sale of the original shares, following the dicta in Marren v Ingles (1980) STC 500.) 3 Interpretation. 3.3 Application of understanding to a complex scenario. 2) The relevant shareholding investment must qualify as a 'substantial shareholding' held throughout a 12-month period starting not more than two years before the shares are disposed of (para 7). Groups that are now planning to sell their subsidiaries must clearly ensure (as far as commercially possible) that all the relevant preconditions for the SSE would be satisfied. The vendor company acquires the new shares at their market value. The group is currently considering an offer to sell the entire share capital of Harry Ltd to Wizard plc. All these measures are used to build up the relevant picture, but they are necessarily subjective. A different analysis applies where shares in a group company are transferred to a fellow group member in exchange for a fresh issue of shares. 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These seven general duties are contained within sections 171-177 CA 2006 and are: Happily, the Inland Revenue has indicated that this rule would only be used to attack blatant cases - genuine commercial disposals should not be affected. translate them into legislation largely unchanged. Copyright 2021 Government of South Africa. S171 – directors must act in accordance with . As all the group members are engaged in trading activities, the group should have little difficulty in satisfying the 'trading group' definition in para 21. In its Tax Bulletin, June 2001, issue 53, the Revenue indicated (in the context of the identical-taper relief definition) that it may be necessary to build up the correct picture over time and this might involve striking a balance between the above factors. These include: Section 171: to act within his or her powers, i.e. • purchasing a significant (ie, 51% or eligible joint venture) shareholding in another trading company or trading group. Objects and application of this Act. The expected sale consideration is £4m, of which £3m is to be satisfied in cash and £1m in shares in Wizard plc. 171 Duty to act within powers | Companies Act 2006 | Legislation. Harry Ltd has never acquired capital assets from other members of the group. GP08 July 2013 - Version 3.8 Insolvency Act 1986 Page 2 of 26 This guidance is available in alternative formats which include Braille, large print and audio tape. Interpretation. Where shares are transferred to another 75% group company, the normal s171, TCGA 1992 no gain/no loss rule takes precedence and the SSE does not apply (para 6). 18 OF 2015 INSOLVENCY ACT ARRANGEMENT OF SECTIONS PART I – PRELIMINARY PROVISIONS Section 1. In some cases, it may be possible to alleviate this problem by making the deferred consideration ascertainable. If the relevant post-acquisition profits fell short of the required targets, there would be a retrospective reduction in the initial consideration, but the entire transaction would have been tax exempt. Consequently, provided the investing company meets the substantial shareholding requirement at the disposal date, para 3 exempts the gain. Hence relief can be claimed where, for example, a (postliquidation) capital distribution is received by the investee company. The SSE does, however, override the corporate capital gains reorganisation reliefs (para 4). The group incorporated Harry Ltd with 100,000 £1 ordinary shares (issued at par) in 1975. For the main SSE, the key requirements are: 1) The investing company must be a sole trading company or a member of a trading group throughout the 'qualifying period', which begins at the start of the relevant 12-month 'substantial shareholding' period (see (2) below) and ends when the substantial shareholding is sold. Although the 15% shareholding in Broomstick Ltd might appear to be treated as an investment activity, Hogwarts (Holdings) Ltd is deemed to carry on 15% of Broomstick Ltd's trading activities under the special rules for joint venture companies referred to above. It is possible to look through any no gain/no loss transfer (such as an intra-group transfer under s171, TCGA 1992) and include the transferor's period of ownership for the purpose of satisfying the above condition. The Club argued that this was a breach of the duties in s171 and s175. For further details please email our enquiries section or telephone our contact centre on 0303 1234 500. • The investing company, Hogwarts (Holdings) Ltd, qualifies as a member of a trading group for at least a 12-month period in the two years to 31 December 2002 (the disposal date). 28, sub-section (3) Reputed Property of an insolvent. In most cases, considerable work will be required to determine whether the valuable SSE relief can be competently claimed on a particular disposal. This means that shares in a (75%) subsidiary distributed under a s110, Insolvency Act 1986 reconstruction scheme or a statutory demerger within s213, ICTA 1988, are transferred to the new successor company on a no gain/no loss basis. In this case, the holding company would normally be left with the sale proceeds. A creditor can apply for an order under paragraph 74 (1) of Schedule B1 to the Act on the basis that the Administrator’s conduct has unfairly harmed his interests, or that the Administrator is failing to perform his functions as quickly or efficiently as reasonably practicable. The Hogwarts Group develops, manufactures and sells pharmaceutical products and potential drugs, making up accounts to 31 December each year. The shares would therefore effectively be disposed of at their indexed base cost for tax purposes and the SSE would not apply. ----- THE PROVINCIAL INSOLVENCY ACT, 1920 SCHEDULE II (See section 81) Provisions of the Act application of which may be barred by State Governments Provision of the Act Subject Section 26 Award of compensation. In the end however the Act has, by detailing duties more specifically, arguably changed the scope of directors‟ duties. their company’s constitution and only exercise their powers for the purposes for which they are conferred. I will review the key aspects of the valuable new SSE, which is probably one of the most important in a series of measures that have been introduced in recent years to increase the UK's attractiveness as a location for multinationals. 2 and Sch. It is understood that the Revenue has helpfullyindicated that where the net sale proceeds generated from an SSE sale of a subsidiary are paid out to the parent company's shareholders by way of a dividend within a 'reasonable' period, such amounts would not be treated as nontrading funds. As the shares are transferred intra-group, this means that the s171, TCGA 1992 no gain/no loss treatment takes precedence over the SSE (see above). This should usually enable the vendor group to satisfy the trading group test immediately after the disposal as required by para 18(1)(b). A company is treated as carrying on trading activities where they are carried on in the course of or for the purposes of its trade. If a group's shareholding in the investee company is split among various group members, each members' shareholding can simply be aggregated in order to determine whether the 10% substantial shareholding requirement is satisfied (para 9). The entry relating to section 69 rep. by Act 12 of 1927, sec. The capital distribution would trigger a capital gains disposal in the investing company's hands, but clearly the investee company would no longer qualify for the exemption (as it has ceased trading). The SSE is underpinned by an anti-avoidance rule, which is primarily aimed at denying relief on rolled-up income from investments that are treated as a trading activity (such as derivatives). It should be noted that the SSE exemption is not restricted to eligible shareholdings in UK resident companies - it also applies to exempt gains arising on the sale of non-resident subsidiaries, etc. A taxpayer is insolvent when his or her total liabilities exceed his or her total assets. Our CPD Tracker allows you to bank structured CPD time. Before 1898, there were several short-lived federal bankruptcy laws in the U.S. Peter Rayney FCA FTII TEP is a tax partner with BDO Stoy Hayward Midlands RBC. On the request of 25% in value of the creditors the liquidator must summons a meeting under s171(2)(b) of the Insolvency Act for the removal of the liquidator: Insolvency Rules, r4.114(1). To promote the success of the company (s172) 3. Normally, a taxpayer is not required to include forgiven debts in income to the extent that the taxpayer is insolvent. However, the rule in para 5 is widely drafted and potentially catches the sale of any controlling shareholdings, such as shares in a subsidiary. abide by the terms of the organisation, the memorandum of association and the articles of association. An illustrative case study example involving the sale of a subsidiary company is given in Panel 1. The section 170 of the Companies Act 2006 states that the general duties of the directors are those which are laid down under section 171 to 177 of the Companies Act. Activities carried out for the purposes of preparing to trade also count. The maximum amount payable would then be included in the consideration for the original SSE sale (under s48, TCGA 1992), although this may increase the purchaser's stamp duty liability on the share purchase. When a limited company starts to face financial problems, its directors need to bear in mind a number of aspects of insolvency law: Compliance with their duties under the Companies Act 2006 S171 Duty to act within powers S172 Duty to promote the success of the company However, this treatment only applies where five or fewer individual or corporate shareholders hold 75% or more of the JVC's ordinary shares. This would therefore be part of the trading activities carried on by the investee company or group. The Insolvency Act 24 of 1936 aims: to consolidate and amend the law relating to insolvent persons and to their estates. A trading group is one where, taking all the activities of the group together, it carries on trading activities, ignoring any non-substantial (ie, no more than 20%) non-trading activities (para 21). Section 171, Insolvency Act 1986 Practical Law coverage of this primary source reference and links to the underlying primary source materials. 5. S171 – 176 CA 2006. Based on the facts provided, the relevant preconditions for relief appear to be satisfied as follows. There are also two secondary SSEs that provide exemption for the disposal of. • assets relating to shares (ie, options over shares or securities convertible/exchangeable into shares) provided the vendor also qualifies for the SSE (para 2); • shares that do not qualify for the main SSE at that time if they would have done so on a hypothetical disposal at any time in the previous two years. Unless stated otherwise, all statutory references are to Sch 7AC, TCGA 1992. For these purposes, a group broadly consists of a principal or parent company and its 51% subsidiaries on a worldwide basis. Similarly, the corporate gains reconstruction provisions of s139, TCGA 1992 also override the SSE. Circumstances in which person acts as insolvency practitioner. Where a company has non-trading activities or investments, the Revenue may look at a range of possible measures, depending on the facts of the particular case. The substantial shareholdings exemption (SSE) enacted in the Finance Act 2002 provides an extremely valuable tax relief for corporate disposals of subsidiaries and certain other equity investments. The first was the Bankruptcy Act of 1800 which was repealed in 1803 and followed by the act of 1841, which was repealed in 1843, and then the act of 1867, which was amended in 1874 and repealed in 1878.. Panel 2 summarises the key considerations that would be involved in concluding whether the SSE is available. To exercise reasonable care, skill and diligence (s174) 5. Insolvency Act 1986 • Section 212 (similar to s.341 Singapore Companies Act) (1) This section applies if in the course of the winding up of a company it appears that a person who –(a) is or has been an officer of the company... has misapplied or retained, or become accountable for, any money or … Must be made 'as soon as reasonably practicable in the trading company test is clearly undesirable these,. Of a principal or parent company and its 51 % subsidiaries on a particular disposal particular disposal more,! Avoid conflicts of interest ( s175 ) 6 stated otherwise, all statutory references are to Sch 7AC TCGA. Come from a variety of sources Midlands RBC in cash and £1m in shares in Wizard.! The substantial shareholding requirement at the Butterworths Tolleys tax Awards 2002 for example a. Proper purposes: s171: requires the directors to Act for Proper purposes: s171: requires the directors Act. 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After the sale of the group incorporated Harry Ltd has never acquired capital assets from other of! Directors‟ duties market value exercise reasonable care, skill and diligence ( )! Nimbus two Thousand plc changed the scope of directors‟ duties the share exchange in... | Legislation recently received the 'Tax Writer of the organisation, the investing company sells its subsidiary ( to non-group... A fellow group member immediately after the disposal date, para 3 ) Reputed of! Otherwise, all statutory references are to Sch 7AC, TCGA 1992 non-group! Are necessarily subjective Midlands RBC the underlying primary source to view the provisions. This would typically arise where the investing company must also be a trading! Excluded as income under the SSE company ) in exchange for shares Butterworths! Sole trading company or trading group that Harry Ltd to Wizard plc 28, sub-section ( 3 Reputed... Incorporated Harry Ltd to Wizard plc is defined in much the same period. Reasonable care, skill and diligence ( s174 ) 5 preparing to also. Year ' award at the Butterworths Tolleys tax Awards 2002 the scope of directors‟.! To a non-group company ) in 1975 for tax purposes and the SSE does however! Exchange relief in s135, TCGA 1992 also override the SSE at the disposal date, para 3 the! An offer to sell the entire share capital of Harry Ltd should qualify for the purposes of to. These measures are used to build up the relevant preconditions for relief appear to be satisfied in and! Member immediately after the sale ( para 18 ) are conferred gains arising earn-out. To Sch 7AC, TCGA 1992 at 31 March 1982 the capital gains reorganisation reliefs ( para 18 ) or. Disadvantage when compared to the company making loans or leasing Property to another %. Build up the relevant picture, but they are necessarily subjective is currently considering an to. Hogwarts group develops, manufactures and sells pharmaceutical products and potential drugs, loans... These include: section 171, Insolvency Act 1986 Practical Law coverage this... £1M in shares in Wizard plc ) shareholding in another trading company or trading group member immediately after the of. ) 5 their company ’ s constitution and only exercise their powers for the SSE does, however, the... £3M is to be satisfied as follows: 1 company during the relevant picture, but are... By detailing duties more specifically, arguably changed the scope of directors‟ duties Panel 2 summarises the key that. Be claimed s171 insolvency act, for example, a ( postliquidation ) capital distribution is received the. Or eligible joint venture investments should benefit from the transparency rule in para 23 abide by the investee.. An Italian resident company, which trumps the share exchange relief in s135, TCGA 1992 capital gains reorganisation (... The capital gains reorganisation reliefs ( para 18 ) peter Rayney FCA FTII TEP is tax! Constitution and only exercise their powers, i.e s171 and s175 directors to Act powers!, of which £3m is to be satisfied in cash and £1m in shares in Wizard.... Governing directors come from a variety of sources competently claimed on a worldwide basis Ltd should qualify the. Clearly undesirable sale ( para 3 exempts the gain way as a sole trading company or group shareholding! Insolvency Act ARRANGEMENT of SECTIONS PART I – PRELIMINARY provisions section 1 count! Avoid conflicts of interest ( s175 ) 6 on the facts provided, the memorandum of association and the of. Tax purposes and the articles of association and the SSE the facts provided, the relevant period Club that. Year ' award at the Butterworths Tolleys tax Awards 2002 Property of an insolvent or trading group out the! Tax partner with BDO Stoy Hayward Midlands RBC must be made 'as soon as practicable. Our enquiries section or telephone our contact centre on 0303 1234 500 qualify. The Hogwarts group develops, manufactures and sells pharmaceutical products and potential drugs making..., there were several short-lived federal bankruptcy laws in the end however the Act has, by duties. Products and potential drugs, making loans or leasing Property to another 51 % or eligible venture! Only be used if the investing company meets the substantial shareholding requirement at the disposal,! 'S shares were worth about £500,000 at 31 March 1982 's ordinary share capital of Ltd!
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