Tax structuring.
Tax structuring of transactions, reorganisations and holdings — including mergers, demergers and buy-backs.
About this service.
Buyers, sellers and target entities in reorganisations, demergers, slump sales, buy-backs and capital reductions.
Tax structuring addresses the way a transaction, entity or group is organised so that the tax outcome is efficient and compliant. It applies to acquisitions, reorganisations, capital changes and the holding structure of a business.
Engagements include evaluating tax-neutral reorganisation structures (such as those under sections 47, 72A and 79), slump-sale and itemised-sale structuring, and the interplay of buy-back, capital reduction and dividend distribution.
Particular attention is given to the General Anti-Avoidance Rules (GAAR), specific anti-avoidance provisions, and stamp-duty and indirect-tax consequences of the chosen structure.
What the engagement covers.
Tax-neutral merger and demerger structures
Slump-sale and itemised-sale structuring
Buy-back and capital-reduction tax planning
Holding and group-structure advisory
GAAR and SAAR application review
Stamp-duty and indirect-tax structuring inputs
Applicable laws and standards.
Other tax services.
Top questions.
The questions clients most often ask about this service. For anything specific to your situation, write to the firm.
Organising a transaction, entity or group so the tax outcome is efficient and compliant.
Mergers, demergers, slump sales, buy-backs, capital reductions and the holding structure of a business.
Reorganisation provisions such as sections 47, 72A and 79 of the Income-tax Act, read with Companies Act scheme procedures.
Yes. Stamp-duty and indirect-tax consequences form part of the analysis.
Yes. Structures are tested against GAAR and specific anti-avoidance rules.
Yes. The tax interplay of buy-back, capital reduction and dividend distribution is evaluated.
No. The firm coordinates with legal counsel on documentation and scheme filings.
Not necessarily. Treatment depends on the structure and is assessed on a case-by-case basis.
Buyers, sellers and target entities in reorganisations, demergers, slump sales and capital changes.
Before the transaction is finalised, so the structure can be optimised and documented.
Looking for tax structuring support?
Write to the firm to discuss the engagement. Each engagement is scoped through a formal letter, preceded by independence and conflict-of-interest checks.