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Debt Buy-Backs

Following up their article on HM Treasury's recent proposals on debt buy-backs Anneli Collins and David Gordon of KPMG LLP comment on HMRC's recently issued draft legislation and related guidance
As discussed in Issue 1002 of The Tax Journal (dated 26 October 2009) the Financial Secretary to the Treasury announced on 14 October that the Government intends to change the legislation dealing with the tax treatment of companies buying back their debt at a discount with the stated intention of tightening the rules to ensure that only those debt buy-backs that are undertaken as part of genuine corporate rescues will benefit from the discount not being subject to tax.
It was noted at that time that the nature of the announcement (without related draft legislation guidance or...

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