In Euromoney, the FTT held that the share for share exchange provisions of TCGA 1992 s 135 applied to the transaction in question. They were not disabled by the main purpose test in TCGA 1992 s 137, even though the avoidance of a tax liability was one of the taxpayer’s purposes. In contrast to the approach taken in Snell, the FTT thought it appropriate to consider everything that forms part of the arrangements in a wider commercial sense, not only the tax-motivated steps.
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In Euromoney, the FTT held that the share for share exchange provisions of TCGA 1992 s 135 applied to the transaction in question. They were not disabled by the main purpose test in TCGA 1992 s 137, even though the avoidance of a tax liability was one of the taxpayer’s purposes. In contrast to the approach taken in Snell, the FTT thought it appropriate to consider everything that forms part of the arrangements in a wider commercial sense, not only the tax-motivated steps.
If you are not a subscriber, subscribe now to read this content.
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