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At a glance

The Transactions in Securities (TiS) rules are anti-avoidance rules. When triggered a profit or gain is taxed as income, denying any generally more favourable Capital Gains Tax treatment.

The TiS rules have evolved over time. Finance Act 2016 introduced new targeted rules.

Finance Act 2016 changes, these:

  1. Widened the existing TiS rules to counteract a tax advantage when a person contrives to receive a consideration in respect of shares as capital rather than income.
  2. Introduced a new Targeted Anti Avoidance Rule (TAAR) which applies to distributions in respect of share capital in a winding-up in order to combat 'phoenixing'. Although not specifically within the TIS rules (it is in ITTOIA 2005), it will when it applies, result in an Income Tax charge arising where capital gains tax might otherwise have applied. 
  3. Amended the process that HMRC is required to follow to counteract a tax advantage is changed.

Index to our guides

Targeted Anti-Avoidance rule (TAAR): Distributions on winding up

Transactions in Securities

Transactions in Securities case studies

More useful guides

 

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