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Anti-Avoidance and Land

Bas Kundu Tax Director and Grant Beaumont Tax Manager in KPMG's Real Estate Advisory Services review the application of s 776 to property transactions
ICTA 1988 s 776 was introduced to prevent the avoidance of tax for property transactions undertaken to realise a profit but disguised as capital transactions. Transactions that take place with the intention of making a profit similar to that realised by a dealer in property but which are achieved by means that cannot easily be considered to be in the nature of a trade could be potentially exploited by taxpayers in the absence of this section.
Despite its apparently far-reaching tentacles this section has been scantly litigated since the early 1980s. There could be a number of reasons for...

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