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13 June 2017

Issue: 4603 / Categories: Forum & Feedback

Correspondence from readers on topical subjects.

More feedback on buybacks

I have read Sara Cohen’s recent article (see ‘Buybacks revisited’ 11 May 2017 page 10) and further comments (‘Feedback’ 1 June 2017 page 20). Originally I thought her article ‘Multiple attraction’ (13 October 2011 page 14) said all that was needed. However she has pointed to the November 2016 edition of Tolley’s Practical Tax Newsletter from which it seems that HMRC is still trying to prevent a single exchange multiple completion share buyback being effective.

In general I still agree with Sara that there should be a disposal at the time of the original single exchange multiple completion contract. However I am less sure about the reasoning given in the article. I agree that TCGA 1992 s 22 cannot apply and for the reasons given in the 1 June issue. However I do not...

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Feedback

© Copyright LexisNexis 2024. All rights reserved.

13 June 2017

Correspondence from readers on topical subjects.

More feedback on buybacks

I have read Sara Cohen’s recent article (see ‘Buybacks revisited’ 11 May 2017 page 10) and further comments (‘Feedback’ 1 June 2017 page 20). Originally I thought her article ‘Multiple attraction’ (13 October 2011 page 14) said all that was needed. However she has pointed to the November 2016 edition of Tolley’s Practical Tax Newsletter from which it seems that HMRC is still trying to prevent a single exchange multiple completion share buyback being effective.

In general I still agree with Sara that there should be a disposal at the time of the original single exchange multiple completion contract. However I am less sure about the reasoning given in the article. I agree that TCGA 1992 s 22 cannot apply and for the reasons given in the 1 June issue. However I do not...

Only subscribers may read the full article

Subscribe Now...

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.

Once you have registered, you will receive an email directing you back to read this item in full.

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4603

Categories: Forum & Feedback [1]

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