Paper for paper treatment clearances

Produced by Tolley

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

Paper for paper treatment 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 trea

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