Commentary

D7.4103 Financing-arrangement-funded transfers to shareholders

Corporate tax
Corporate tax | Commentary

D7.4103 Financing-arrangement-funded transfers to shareholders

Corporate tax | Commentary

D7.4103 Financing-arrangement-funded transfers to shareholders

The rules in this division apply for accounting periods beginning on or after 1 January 2013. For accounting periods beginning before 1 January 2013 see Division D7.5.

Special transitional rules are provided for the relief of any unrelieved charge under FA 1989, s 83YC on transition to the new regime. Any such amount will not be identified by the mechanics for calculating the total transitional difference because it is a fiscally created tax charge not generated by entries in either the company's statutory accounts or regulatory return1. Under the current rules such charges unwind as the

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