Finance Act 2016 included a raft of new measures that were,broadly, intended to make sure that the UK exchequer obtained the full amount of tax on trading profits which had as their subject matter UK land. The relevant rules are widely drawn to make sure that ‘disguised’ trading, whether by ‘enveloping’ or by ‘fragmenting’ the ‘trading’ activity across a number of different persons, is also taxed. Some have argued that the rules have been too widely drawn, unexpectedly covering buy-to-let transactions. However, a proper consideration of the wider statutory context suggests that such concerns might be overstated.
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Finance Act 2016 included a raft of new measures that were,broadly, intended to make sure that the UK exchequer obtained the full amount of tax on trading profits which had as their subject matter UK land. The relevant rules are widely drawn to make sure that ‘disguised’ trading, whether by ‘enveloping’ or by ‘fragmenting’ the ‘trading’ activity across a number of different persons, is also taxed. Some have argued that the rules have been too widely drawn, unexpectedly covering buy-to-let transactions. However, a proper consideration of the wider statutory context suggests that such concerns might be overstated.
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