How to Restructure Your Company Tax-Efficiently — Holding Company Insertion, Demergers, and Share-for-Share Exchanges (2026)
The main tax-efficient corporate restructuring tools in the UK: Section 110 Insolvency Act reconstruction, Section 135 share-for-share exchange (inserting HoldCo without CGT), Section 127 reorganisation relief.
The main tax-efficient corporate restructuring tools in the UK: Section 110 Insolvency Act reconstruction, Section 135 share-for-share exchange (inserting HoldCo without CGT), Section 127 reorganisation relief. Demergers: partition of a trading group into separate companies. Each has specific conditions — professional advice is essential. This article explains when each restructuring tool applies and what the tax implications are.
This content is educational and does not constitute legal or tax advice. Always consult a qualified professional for your specific situation. Data last verified March 2026.