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By Richard Bramwell QC, John Lindsay, Alun James, Julian Hickey, Michael Collins

Published by Sweet & Maxwell

As a tax consultant and a regular user of 'Taxation of Companies and Company Reconstructions' since my first review in 2006, I have to say that I have found this publication very useful in my corporate tax advisory work over the years. Those involved in corporation tax (and company reconstruction work in particular) to a significant extent should find it a valuable addition to their tax library (if they do not possess a copy already).

'Taxation of Companies and Company Reconstructions' is a weighty, three volume looseleaf publication. Its content is as comprehensive as its considerable size suggests. The publication is separated into divisions in alphabetical order (A-W) (albeit that Divisions ‘F’, ‘I’ and ‘N’ were missing from my copy), which are subdivided into readable chapters. The divisions are listed at the end of this review. Users will no doubt have their own ‘favourite’ divisions of this publication, as some divisions will be more relevant to their day-to-day corporate tax work than others. The most helpful divisions in my day-to-day consultancy work are: A (Corporation tax), D (Close companies), E (Distributions), G (Intangible fixed assets), K (Loan relationships) and W (Reconstructions).

One of the most regularly used divisions of this publication for me is the final one on reconstructions, not least because of the 'transactions in securities' anti-avoidance provisions (at W6). Looking through this chapter, I have previously highlighted various passages in my work. Another chapter which has been invaluable is W3 (‘Reconstructions: shareholdings and asset transfers’). Division E on distributions includes a chapter (E4) on companies purchasing their own shares, which has been another regular part of my work over the years. These are just a few of the chapters I find particularly useful. However, generally speaking there should be something for everyone who is involved in corporate tax and tax planning to any significant extent.

Corporation tax is one of the faster moving areas of taxation, and up-to-date commentary is therefore vital. One of the benefits of a looseleaf publication (compared to a hardback annual) is that it can be regularly updated. 'Taxation of Companies and Company Reconstructions' is updated three times a year, and so lends itself well to a looseleaf format. A useful component of each update is a summary of the new contents, which represents a helpful aide memoire of recent corporation tax changes (perhaps the publishers could email this summary to subscribers as well?).

I understand that an online version of 'Taxation of Companies and Company Reconstructions' is available via the Westlaw service. At present, there is no CD version of this publication as far as I am aware; this would be a useful addition for subscribers.

As the calibre of the authors suggests, the commentary in 'Taxation of Companies and Company Reconstructions' is written to a very high technical level. The one aspect of this publication that perhaps impresses me most is that, despite the technical complexity of the subjects covered, the commentary is written in plain, everyday language (so far as the subject matter allows) and in a manner which is precise, and easy to digest and understand. As a tax author myself, I can appreciate how difficult this can be to achieve, and congratulate the authors on their success; the names of those authors on the cover of the publication will be familiar to many in the tax profession. The commentary includes footnotes for statutory references etc, and there are numerous examples, and even diagrams where appropriate, to assist comprehension further.

In summary, 'Taxation of Companies and Company Reconstructions' is a high quality, high level publication. It is surely a leading publication of its kind, and a 'must have' for the corporation tax specialist. It should also be a useful addition to the tax library of non-specialist practitioners with corporate clients, especially when exposed to corporation tax issues which are perhaps unusual and outside the scope of their day-to-day work, particularly corporate restructuring work.    

The cost of ‘Taxation of Companies and Company Reconstructions’, including three updates a year, is £935. Tax publications generally tend to be relatively expensive, but the cost of this tax publication is at the higher end of the scale. However, in this case the cost is perhaps a reflection of the quality of the publication and the expertise of its authors. Those who advise on corporation tax and company reconstructions should find it a worthwhile investment. 

For completeness, the divisions of ‘Taxation of Companies and Company Reconstructions’ are as follows:

A: Corporation Tax
B: Compliance and Litigation
C: Capital Allowances for Plant and Machinery
D: Close Companies
E: Distributions
G: Intangible Fixed Assets
H: Derivatives
J: Transfer Pricing
K: Loan Relationships
L: Deemed Loan Relationships and Stock Loans
M: Worldwide Debt Cap Legislation
P: Non-Resident Companies
Q: Controlled Foreign Companies (CFCs)
R: Double Tax Relief
S: EU Law  
T: Group Relief
V: Group CGT and SDLT
W: Reconstructions

Further information and ordering details are included on the Sweet and Maxwell website: Taxation of Companies and Company Reconstructions

Mark McLaughlin CTA (Fellow) ATT (Fellow) TEP

Managing Editor, TaxationWeb