The Foreword to Taxation of Companies and Company Reconstructions makes the point convincingly that “ … current legislation is setting new standards of impenetrability… “. In that domestic climate, and also the context of the Maastricht Treaty, the authors aim to cover the whole spectrum of taxation of companies. The book is divided into three parts: taxation of companies; groups and consortia; and company reconstructions. Each part has an introductory chapter, and each topic is treated as discrete, with an explanation which is never legalistic. The authors’ style is concise, as, for example, their discussion of the validity of gifts and the relevant aspects of the “old” and “new” ultra vires rules in less than two pages (paras 11.30–11.31). It is also direct, practical and comprehensive throughout, but notably on companies purchasing their own shares (Chap. 13, debating SP 4/89 and including the Inland Revenue’s reply to Authors’ letter (para. 13.25)), group relief (Chap. 22), pre-entry losses (Chap. 24, with 22 examples), demergers (Chap. 28) and break-up bids (Chap. 33). The footnotes are refreshingly succinct, avoiding the kind of intellectual cadenza which is supposed to be the hallmark of academic writing.

When relying upon a practical exposition such as this, the reader should be totally confident that the index and cross-references in the text are comprehensive. In this respect, however, there is scope to suggest an improvement. One of three references to ships includes the statement: “Ships and motor cars are subject to their own sets of rules which are outside the scope of this chapter [Capital Allowances for Plant and Machinery]: see sections 30–36 and 41 of the Capital Allowances Act 1990” (para. 5.13). It is arguable that at least a footnote should explain specifically that the 1990 Act, Chap. II (ss 30–33) covers ships and first-year allowances, writing down allowances (s. 31), ships not used in the actual trade, and the exclusion of s. 31. There should also be a cross-reference in particular to ss 37(l)(b) and 38 (paras. 5.12 and 5.42).

Likewise, in connection with the charge to corporation tax and computation of profits of oil exploitation companies, there is a statement that “[T]he provisions contained in Chapter XII of Part V [of the Taxes Act 1988] govern the taxation of such companies [etc]” (para. 2.32), without noting that the 1988 Act, Chap. V (ss 492–502) deals with taxation of oil extraction activities, valuation of oil disposed of or appropriated, charges on income, regional development grants, tariff receipts, and aspects of advance corporation tax and petroleum revenue tax. Nor is there any cross-reference to para. 12.13, in which a footnote draws express attention to special restrictions on ACT set-off for such companies.

Furthermore, the style of the index is not always clear. Under “Double Taxation”, EU law contains an instruction “See also European Union”, and subsidiaries and branches within the EU a similar instruction to “[S]ee also EU law: European Union”. Neither reference appears to have been indexed as a substantive heading. Instead, the latter is to be found in the table of contents at the start of Chapter 17.

Although the choice of these three examples can be criticized as highly selective, they leave the reader with a sense of possible minor, but false, economies in such a detailed account of the law. An authoritative textbook, such as this, should not create the impression (whether correct or misguided) that the reader may be obliged to check the contents or table of statutes in order to trace further information, nor that the extent of the index may be limited.

That said, this sixth edition includes a full analysis of the Taxation of Chargeable Gains Act 1992, the Finance Acts 1992–1994, the various consequences of R. v. IRC, ex p. Commerzbank A.G. [1993] S.T.C. 605 (E.C.J.) and other recent decisions. The copious tables, examples, diagrams, flow charts, and references to Inland Revenue Statements of Practice ensure that this book is invaluable