Miller, Hardy and Ismail on Company Reorganisations

By George Hardy, Pete Miller, Fehzaan Ismail

Now in its 7th Edition, Miller, Hardy and Ismail on Company Reorganisations (previously Taxation of Company Reorganisations), is an essential reference source for tax advisers that covers the basic rules of corporation tax and capital gains, reorganisations, share exchanges and other deemed reorganisations, reconstructions, mergers, demergers and branch incorporations, as well as cross-border transactions. It is one of the leading UK commentaries on dealing with all aspects of reorganising a company.

Readers will benefit from the practical expertise and guidance of the authors, gained in over 50 years of practical experience dealing with corporate tax transactions for clients of all sizes.

A variety of topics are discussed, from the reduction of capital rules, and interaction with substantial shareholding exemption, to qualifying corporate bonds (QCBs), reconstruction reliefs, and UK and cross-border mergers. The commentary is supported by a series of easy to follow diagrams and flowcharts.
The new edition brings the commentary up-to-date with recent Finance Acts including new provisions relating to share exchanges involving non-UK incorporated close companies introduced in Finance (No.2) Act 2023; and relevant new guidance from HMRC. There is also a new Chapter on the multinational top-up tax and domestic top-up tax provisions as these apply to reorganisations.

A number of important new cases are also analysed, including the following:
- Euromoney Institutional Investor PLC (FT): Anti-avoidance on exchange of shares
- Gallaher (various including UT and CJEU): intra-group transactions and EU law
- Kavanagh (FT): Holding shares on trust
- Blackrock (UTT), Oxford Instruments (FTT), and Kwik Fit Group Ltd (UT): unallowable purpose test
- Altrad Services (UT): disclosed avoidance scheme
- M Group Holdings (FTT): substantial shareholding exemptions

Pete Miller is the Head of Corporate Tax at Jerroms Miller, a specialist tax advisory formed by the merger of the corporate transaction tax team of Jerroms and The Miller Partnership (which Pete founded in 2011).

George Hardy is a retired partner of Ernst & Young, where he specialized in financial services. He is now researching a book on the philosophical foundations of AI .

Fehzaan Ismail is a Partner in EY's International Tax and Transaction Services team and advises clients in the Financial Services sectors.

• Format: Paperback
• Language: English
• ISBN: 1526529653
• ISBN13: 9781526529657
• Release Date: March 2026
• Publisher: Tottel Publishing
• Length: 752 Pages
• Weight: 1.00 lbs.
• Dimensions: 1.0" x 6.1" x 9.2"