Transactions in Securities - A Road Map with Philip Ridgway

Transactions in Securities - A Road Map with Philip Ridgway


6 Jun 2024

1:30 PM ‐ 4:30 PM

With a SmartPlan £243

With a Season Ticket £270

Standard price £360

All prices exclude VAT
Update: Requires no prior subject knowledge
3 hours
Group bookings
email us to discuss discounts for 5+ delegates


Even the simplest of transactions can give rise to potential issues with transactions in securities legislation. There has recently been a renewed focus on the rules as HMRC appear to have altered their stance on giving clearance and a raft of counteraction notices have been issued for transactions undertaken in early 2016.

This 3 hour virtual classroom session, presented by Philip Ridgway of Temple Tax Chambers, seeks to demystify the legislation and caselaw and to provide a road map as to when the legislation will apply and the consequences of it doing so.

What You Will Learn

This live and interactive course will cover the following:

  • Setting the scene
    • A brief history of the Transactions in securities rules
    • The view from 30,000 feet and the mischief aimed at
  • Looking at the legislation
    • Conditions necessary for the rules to apply
    • Relevant consideration
    • Tax advantage
    • The distribution limitation
    • What are: ‘profits available for distribution’?
  • If you’re looking for a way out
    • Main purpose not the avoidance of tax - aka the motive test
    • Fundamental change of ownership
  • Looking at the cases
  • Some common transactions - and the attendant issues
    • Share Exchanges
    • Purchase of own shares
    • Management buy-outs
    • Reductions of capital
    • Sales to an EOT
  • Clearance
  • Counteraction
  • Appeals

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.