On 25 July, following discussions with the CIOT, HMRC updated its Company Taxation Manual (CTM36330 and CTM 36340) in relation to the targeted anti-avoidance rule for distributions on a winding-up introduced by Finance Act 2016. The bulk of the changes provide more detail on the main purpose test in condition D.
The CIOT and ATT have also published a short commentary on the changes (see https://bit.ly/2LVGbL6).
On 25 July, following discussions with the CIOT, HMRC updated its Company Taxation Manual (CTM36330 and CTM 36340) in relation to the targeted anti-avoidance rule for distributions on a winding-up introduced by Finance Act 2016. The bulk of the changes provide more detail on the main purpose test in condition D.
The CIOT and ATT have also published a short commentary on the changes (see https://bit.ly/2LVGbL6).
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