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Capital allowances: anti-avoidance
On 21 July 2009 the Financial Secretary to the Treasury Stephen Timms announced action 'to counter tax avoidance schemes involving capital allowances on plant or machinery.
'Legislation will be introduced in the 2010 Finance Bill to prevent tax avoidance through the transfer of an entitlement to benefit from capital allowances on plant or machinery used for the purpose of a trade where the tax written down value of the plant or machinery exceeds its balance sheet value (“latent capital allowances”).
'The proposed legislation will apply where there is a change of ownership of a company as part of arrangements one of the main purposes of which is to transfer to the purchasing group an entitlement to benefit from the latent capital...

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