Commentary

267 Tax advantages from transactions in securities

COMPANIES vol 11 acquisitions, mergers, demergers
| Commentary

267 Tax advantages from transactions in securities

| Commentary

(c) Anti-avoidance provisions

267 Tax advantages from transactions in securities

When parties to a company reconstruction are applying for advance clearance in respect of Section 733 of the Corporation Tax Act 2010 or Section 136 of the Taxation of Chargeable Gains Act 1992, it is also usual to ask for clearance in relation to tax advantages derived from transactions in securities under the Corporation Tax Act 2010 and the Income Tax Act 20071. Where a transaction falls within one of the prescribed circumstances, HM Revenue and Customs may counteract any tax advantage by assessing the relevant person to income tax2. The

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