Transactions in Securities – What’s the Deal?

‘Without question the best tax lecturer I have ever encountered, with MBL or elsewhere’


Many common transactions have the potential to fall foul of the transactions in securities legislation, which has been with us since FA 1960. While the rules probably no longer apply to corporation tax payers, the majority of transactions ultimately involve income tax payers and HMRC’s attitude is sometimes unhelpful.

This half-day course will take you through the legislation and give practical advice on transactions affected and how to deal with them, including getting a pre-transaction clearance from HMRC.

What You Will Learn

  • Introduction
    • Tax avoidance – some background
    • The mischief: why was the legislation introduced
    • Application to income tax
    • Why the rules probably don’t apply to corporation tax
  • How the income tax rules work
    • Conditions for the rules to apply
    • Types of transaction affected
    • Specific transactions
    • Quantum of tax advantage
  • The escape clauses
    • Tax avoidance motive
    • Change of ownership test
  • Counteraction of tax advantages
    • Counteraction notices – the process
    • Appeals
  • Pre-transaction clearances application
    • Contents
    • Disclosure
    • Timing
    • Refusal of clearance

Book Here:—Whats-the-Deal$/3802

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