Whether motivated by activist pressures, management focus or balance sheet clean ups, spin offs and demergers are an actively employed management tool to dispose tax efficiently of a line of business

• the impact of cross-border distributions in division of multinational business;
• divisional carve-outs or hive downs;
• restructuring of debt and contingent liabilities among retained and disposed businesses;
• tax aspects of divisional carve-outs or hive downs;
• sales or initial public offering (IPO) combined with spin-offs or other dispositions, such as spin merge transactions;
• allocation of intangibles; and
• the impact of EU directives on both corporate law structures and tax consequences.