A hive of activity

Jack Hollyman considers how to manage the commercial and tax issues when transferring business assets and shares to a purchasing company

It always sounds so simple: ‘Hive down the trade and assets into a new company (‘Newco’) and dispose of Newco to a buyer, tax free’. But, of course, there are a host of commercial and tax issues to consider and navigate. The commercial aspects of a hive down, while burdensome, are generally well understood and managed upfront. For example, some of the key commercial areas of focus are: