- Examining proposed changes to share-for-share tax relief
- Original news
- What is the context of this proposed amendment?
- What does the new change to stamp duty share-for-share relief in FA 1986, s 77 do?
- Why was this new condition added without notice or consultation?
- What mischief does the government intend to prevent by adding this further condition?
- Following this change, what types of structuring would be at risk or no longer be possible?
- Do you foresee any collateral damage?
- Given that ‘arrangements’ do not need to be legally enforceable or in writing, what guidance is available on when an arrangement to transfer control of the acquiring company is in existence?
Tax analysis: Michael Quinlan, barrister at Temple Tax Chambers who specialises in transaction taxes involving real estate and securities, examines the potential amendments to sections 77 of the Finance Act 1986 (FA 1986).
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