Transactions in Securities - What's the Deal?
Many common transactions have the potential to fall foul of the transactions in securities legislation, which has been with us since FA 1960. There has been a renewed focus on counteraction since 2010, as well as changes to the legislation in 2001 and 2016. This practical 3 hour seminar will take you through the current form of the legislation and explain what transactions are being challenged by HMRC and why.
What You Will Learn
- Tax avoidance background
- The mischief: why was the legislation introduced
- Application to income tax
- How the income tax rules work
- Conditions for the rules to apply
- Types of transaction affected
- Quantum of tax advantage
- The escape clauses
- Tax avoidance motive
- Change of ownership test
- Problem areas
- Management buy-outs
- Reductions of capital
- Share exchanges followed by reductions of capital
- Use of EBTs as a ‘market’ for shares
- Counteraction of tax advantages
- Interaction with anti-phoenix TAAR
Please let us know if you wish to be notified.
Please let us know if you wish to be notified when new dates are added for this programme