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Chargeable gains: draft guidance

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Comments are invited by 22 February 2011 on draft HMRC guidance on proposed changes to the rules governing taxation of companies’ capital gains.
The guidance will be published in HMRC’s Capital Gains Manual. It describes proposed measures, to be included in Finance Bill 2011, relating to:

  • the value shifting rules;
  • the de-grouping charge; and
  • losses following a change of ownership.

In a summary of responses to recent consultation, HMRC and the Treasury said respondents were ‘generally supportive’ of the proposals. There was ‘broad agreement’ with the assessment that an important benefit of the simplification proposals would be to improve certainty for taxpayers, though ‘there would not be a significant change to the administrative burdens involved’.

A number of technical changes were made to the draft legislation as a result of respondents’ comments.