Transactions in Securities

Pete is an expert on the Transactions in Securities anti-avoidance rules, which impact almost every transaction and are often the sticking point in getting an HMRC clearance for a transaction. Pete is the author of Tolley’s Tax Digests 81 and 92 on Transactions in Securities, covering the rules from before and after the changes introduced by FA 2010.

The rules for individuals were largely re-written in 2010 and Pete’s input into HMRC’s consultation had a significant impact on the shape of the new rules.

Case Study

We have been working on cases involving returning capital to shareholders and trying to overturn HMRC’s incorrect view that the Transactions in Securities rules apply in such cases.