Commentary

D4.743 Receipts cases—scope and tax implications

Corporate tax
Corporate tax | Commentary

D4.743 Receipts cases—scope and tax implications

Corporate tax | Commentary

D4.743 Receipts cases—scope and tax implications

The provisions in this article were repealed from 1 January 2017. From 1 January 2017, the rules dealing with hybrid and other mismatches apply; see D4.701 onwards. The latter rules were introduced as part of the OECD BEPS action plan on international corporate tax avoidance.

The receipts cases provisions have effect in relation to any contribution to the capital of a company resident in the UK that is made on or after 16th March 20051.

If HMRC consider, on reasonable grounds, that each of the following conditions are or may be satisfied in relation to a company resident in the UK, they may give the company a notice as described

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