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