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Burges Salmon

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Tax rewrite

I recently wrote to HMRC asking whether the wording of ITTOIA 2005, s 397(1) had changed the meaning of TA 1988, s 486 (1). The reference to 'share interest ... payable by a registered industrial and provident society (IPS)' has been replaced by 'payment to a shareholder in such a society'. Potentially this could cover, for example, a payment by one member of the IPS to another.

Confirming that the wording had not changed the interpretation, HMRC gave this explanation:

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