The FTT in Euromoney finds in favour of the taxpayer that ‘arrangements’ in the context of TCGA 1992 s 137 should be interpreted widely in the context of the overall deal with the result that the tax avoidance purpose was not a main purpose. The FTT in M Group Holdings Ltd agrees with HMRC’s long-held view that the substantial shareholding exemption is not available where the transferee company is a newly acquired subsidiary of what was previously a single trading company. Finance Bill 2021 has completed its committee stage and amendments have been made, including to the hybrids rules. HMRC updates its stamp taxes guidance to confirm that the confirmation letter from HMRC is sufficient evidence that an instrument of transfer submitted electronically is duly stamped and there is no need to re-submit the physical documents for stamping post-covid.
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The FTT in Euromoney finds in favour of the taxpayer that ‘arrangements’ in the context of TCGA 1992 s 137 should be interpreted widely in the context of the overall deal with the result that the tax avoidance purpose was not a main purpose. The FTT in M Group Holdings Ltd agrees with HMRC’s long-held view that the substantial shareholding exemption is not available where the transferee company is a newly acquired subsidiary of what was previously a single trading company. Finance Bill 2021 has completed its committee stage and amendments have been made, including to the hybrids rules. HMRC updates its stamp taxes guidance to confirm that the confirmation letter from HMRC is sufficient evidence that an instrument of transfer submitted electronically is duly stamped and there is no need to re-submit the physical documents for stamping post-covid.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
