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Finance Bill: New anti-avoidance rules to take effect from 20 March 2013

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A number of anti-avoidance measures announced in last week’s Budget will take effect from Budget day, 20 March, and a measure to counter stamp duty land tax avoidance will take effect for transfers of rights taking place on or after 21 March 2012.

Corporation tax loss relief (‘loss buying’)

Legislation in the Finance Bill will restrict relief for losses surrendered within a group and the availability of relief where there is a change of company ownership.

Corporation tax deductions for employee share acquisitions

The Finance Bill will clarify rules determining availability of corporation tax deductions where companies grant share options or award shares to their employees.

Close company loans to participators

The Finance Bill will counter certain arrangements seeking to avoid the charge under CTA 2010 s 455.

Stamp duty land tax avoidance

HMRC said that despite the chancellor’s warning at Budget 2012 of retrospective legislation to close future SDLT schemes, two particular schemes that ‘abuse’ the transfer of rights (or subsale) rules had been growing ‘increasingly popular’. A measure to close down these schemes will have effect where the transfer of rights takes place on or after 21 March 2012 and before Royal Assent to Finance Bill 2013.

HM Treasury and HMRC guidance

Details are set out on HM Treasury’s website.