Transactions in securities clearances

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

Introduction to TIS clearances

The transactions in securities (TiS) legislation gives HMRC the power to issue a notice of counteraction in respect of a tax advantage arising from specified scenarios. Broadly it applies where a transaction is carried out otherwise than for bona fide commercial reasons of which the main object is to obtain a tax advantage. There is no obligation to seek clearance from HMRC in relation to TiS and potential applicants may decide not to do so. For more information on the TiS legislation, including a summary of situations where the rules should not apply, see the Transactions in securities and the Phoenix TAAR ― outline of regime guidance note.

A statutory clearance procedure is available under ITA 2007, s 701 (income tax) and CTA 2010, s 748 (corporation tax) and provides confirmation that HMRC will not issue a counteraction for the transaction in question. A clearance application generally takes the form of a letter or email to HMRC setting out the

Continue reading the full document

To gain access to additional expert tax guidance, workflow tools, and tax research, register for a free trial of Tolley+™

TAKE A FREE TRIAL NOW

Popular Articles

Owner-Managed Businesses

Tax implications of administration and liquidation

Tax implications of administration and liquidationThis guidance considers the tax implications of a company going into administration or liquidation.Introduction to company administration and liquidationCompany going into administrationA company which is in financial difficulty may go into

14 Jul 2020 15:29 | Produced by Tolley Read more

Personal Tax

Self assessment ― amendments and corrections

Self assessment ― amendments and correctionsOnce a self assessment tax return has been filed, both HMRC and the taxpayer (or the agent) has the right to make changes to the return. There are different time limits depending on whether it is a correction by HMRC or an amendment made by the

14 Jul 2020 13:37 | Produced by Tolley Read more

Corporation Tax

Qualifying charitable donations

Qualifying charitable donationsCompanies can obtain corporation tax relief for qualifying payments or certain transfers of assets to charity under the qualifying charitable donations regime. Definition of qualifying charitable donationThe definition of ‘qualifying charitable donations’

14 Jul 2020 13:03 | Produced by Tolley Read more

��Ӱ��