Transactions in securities clearances

By Tolley
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The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Transactions in securities clearances
  • Introduction
  • When to seek clearance
  • Other guidance and templates
  • <a class="remotelink" href="/tolley/guidance/corporatetax/linkHandler.faces?linkInfo=F%23GB%23UK_ACTS%23num%252016_24a_Title%25&amp;A=0.7628495328075465&amp;bct=A&amp;ps=&amp;risb=&amp;service=citation&amp;langcountry=GB" target="_parent">Finance Act 2016</a> – effect on TiS clearances already given

Introduction

The Transactions in Securities (TiS) legislation gives HMRC power to issue a notice of counteraction in respect of a tax advantage arising from specified scenarios. Broadly it applies where a transaction is carried out otherwise than for bona fide commercial reasons of which the main object is to obtain a tax advantage. For more information on the TiS legislation, which includes a summary of situations where the rules should not apply, see the Transactions in securities guidance note. A statutory clearance procedure is available under ITA 2007, s 701.

The TiS legislation changed significantly with effect in relation to income tax advantages obtained on or after 24 March 2010. At the time the changes were introduced, HMRC indicated that, as a result, it expected there would be fewer occasions where clearance would be sought. In parti

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