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

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 financing transaction that generated them itself unwinds. Rather than adopting a similar approach on transition and allowing the tax unwind to follow the commercial repayment, any

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