Commentary

D6.612 Capital treatment—scheme or arrangement

Corporate tax
Corporate tax | Commentary

D6.612 Capital treatment—scheme or arrangement

Corporate tax | Commentary

D6.612 Capital treatment—scheme or arrangement

The purchase must not form part of a scheme or arrangement of which the avoidance of tax is the main purpose or one of the main purposes1.

The provisions directed against avoidance of capital gains tax by value-shifting2 must also be considered, having regard to the alteration in the percentage proportions of the remaining shareholdings caused by the cancellation of the shares purchased by the company.

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial