Amongst other goals, such as deduction of borrowing costs or tax-efficient unwinding, the additional step-up depreciation of the underlying assets is an important factor in any acquisition. The tax savings of such additional depreciation increase the cash flow of the target and, therefore, are essential for financing an acquisition.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap