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The implications of the consultation document and proposed legislation on transactions in securities.
KEY POINTS
- HMRC have issued a consultation document and draft legislation on company distributions.
- The new rules should offer clarification and protection.
- The “gateway” provisions of ITA 2007 s 684 to s 687 are amended.
- New rules add to the list of transactions in securities.
- Single purpose vehicles and entrepreneurs who return to a similar business may be caught by the new rules.
Most readers are aware of the transactions in securities rules in ITA 2007 Part 13 Ch 1. Generally these rules are intended to prevent shareholders of a company extracting the funds in capital form when they should (at least in HMRC’s opinion) be paid out as dividend income. For example if I own two companies PeteCo and MillerCo I could take a...
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