Paper for paper treatment clearances

Produced by Tolley
Paper for paper treatment clearances

The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Paper for paper treatment clearances
  • TCGA 1992, s 138 clearances
  • Drafting the clearance
  • Transactions in securities
  • Refusal of clearance ― TCGA 1992, s 138 clearances

TCGA 1992, s 138 clearances

In order for shareholders in a paper for paper exchange to have some certainty as to their tax position, there is a statutory clearance procedure available under TCGA 1992, s 138. This provides that the taxpayer can request clearance that TCGA 1992, s 137 does not apply, ie that the transaction is for bona fide commercial reasons and the main purpose of which is not for tax avoidance. TCGA 1992, s 138 does not provide for a clearance procedure in respect of the other requirements for paper for paper treatment, eg ownership requirements. It

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