Corporation Tax

Transactions in securities clearances

Produced by Tolley
  • 08 Feb 2022 09:26

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

  • Transactions in securities clearances
  • Introduction
  • When to seek clearance
  • Other guidance and templates
  • Refusal of clearance for transactions in securities

Transactions in securities clearances

Introduction

The Transactions in Securities (TiS) legislation gives HMRC power to issue a notice of counteraction in respect of a tax advantage arising from specified scenarios. Broadly it applies where a transaction is carried out otherwise than for bona fide commercial reasons of which the main object is to obtain a tax advantage. For more information on the TiS legislation, which includes a summary of situations where the rules should not apply, see the Transactions in securities and the Phoenix TAAR ― outline of regime guidance note.

A statutory clearance procedure is available under ITA 2007, s 701 (income tax) and CTA 2010, s 748 (corporation tax). A clearance application generally takes the form of a letter or email setting out the steps and anticipated tax implications of the proposed transaction. Once clearance is given

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