The Transactions in Securities (TIS) rules for income tax advantage were rewritten by the 2010 Finance Act.
- The rules give HMRC the power to counteract a tax advantage resulting from transactions made between Close Companies and their owners.
- For the TIS rules to bite the main or one of the main purposes for undertaking a transaction has to be tax avoidance.
- The TiS rules will not apply where the transaction results in a fundamental change in ownership of the company.
TIS contents
Transactions in securities
This Practical Tax guide covers the 2010 changes with detailed examples and sections covering liquidations and ESC C16.
Case studies
A section of cases to illustrate how and when the TIS rules work in practice.
Surplus cash CGT & IHT relief and ESC C16 .
Whilst the TIS rules will cancel a tax advantage obtained when a transaction is taxed under the CGT regime you still have to make sure that CGT treatment is possible.
Extra Statutory Concession C16
This concession allows the profits and reserves distributed during the course of striking off a company to be treated as captial distributions. It is subject to the transactions in securities provisions, and has its own clearance procedure.
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