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The '91B Problem'

 
Anneli Collins and Alison Christian International & Finance Tax KPMG look at the real commercial problems arising from one aspect of the Financial Arrangements anti-avoidance provisions in the Budget
 
Although starting as an innocuous enough statement in the Budget the '91B problem' is fast becoming one of the most talked-about issues in the multitude of new anti-avoidance provisions. Indeed many companies have been looking at it in disbelief for several weeks now. If you have yet to hear the term muttered then brace yourself.
 
Hidden away within Schedule 13 of the original Finance Bill is a provision introducing FA 1996 s 91B. This is aimed at some specific tax planning around converting interest into capital through the use of shares. However as...

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