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25 October 2011 / Pete Miller
Issue: 4327 / Categories: Comment & Analysis , Admin
PETE MILLER asks where we now stand with the complex transactions in securities legislation


  • The basic framework of ITA 2007 s 684.
  • Activities that fall within the definition of a ‘transaction in securities’.
  • The receipt of ‘relevant consideration’ from certain transactions.
  • The exemption where 75% of a shareholding is transferred.
  • Calculating the income tax benefit.
  • Where to find more guidance from HMRC.

The transactions in securities (TiS) anti-avoidance rules are designed to prevent a range of tax avoidance techniques that broadly seek to turn potential income payments into capital payments on the basis that the tax charge on capital gains is usually lower than the income tax on a distribution of the same amount.

The rules are very relevant to the small and medium-sized enterprises (SME) market because they only...

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