Commentary

D8.362 Anti-avoidance provisions

Corporate tax
Corporate tax | Commentary

D8.362 Anti-avoidance provisions

Corporate tax | Commentary

D8.362 Anti-avoidance provisions

Anti-avoidance provisions apply in the two circumstances described below1.

Company reconstructions or amalgamations

Loss relief is not available if the disposal occurs as a result of a company reconstruction that is not effected for bona fide commercial purposes, or that forms part of a scheme for the avoidance of tax2.

Value-shifting

The value-shifting provisions3 apply in a modified form to any disposal when loss relief is claimed. The result is that where a loss has been increased because the shares have been reduced in value following the receipt of any benefit (not merely a tax-free benefit) by the investing

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