TaxCorporate TaxShell finally resolves CGT saga

Shell finally resolves CGT saga

Company agrees to give loan notes to small investors to avoid capital gains liaibility that arose through its restructuring

Royal Dutch Shell has promised small investors either cash or loan notes to
resolve its longstanding tax issues caused by the merger.

When the companies were restructured to form one group rather than two, that
gave rise to a £77m capital gains tax bill as small investors found they had to
sell and repurchase shares, concretising capital gains liabilities.

The company said it would buy out remaining shareholders in its Royal Dutch
arm either with cash or by issuing a loan note, which could be exchanged for
shares that would not incur capital gains tax.

Small investors has complained bitterly about the tax bill. The Association
of Private Client Investment Managers and Stockbrokers, which defends small
investors’ rights, said the move was ‘long overdue’.

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