The transactions in securities (TiS) legislation is anti-avoidance legislation aimed at situations where close company shareholders have engineered a disposal of shares to obtain a beneficial capital gains tax (CGT) rate, ie avoid income tax, on specified transactions.
The targeted anti-avoidance rule (TAAR) aims to combat cases of 鈥榩hoenixism鈥� and applies to certain distributions made in the process of winding up companies. Phoenixism refers to a the same business 鈥榬ising from the ashes鈥� of a company, in other words where a company is liquidated and subsequently its business is carried on under the same or broadly the same ownership via a new entity within two years of the winding-up. Such transactions are likely to also be covered by the TiS regime 鈥� the TAAR was introduced to provide absolute certainty of treatment for such transactions. In practice when there is a company winding up the TAAR may be in point rather than the TiS.
This guidance note discusses some of the TiS and TAAR issues that may be
Payments to trust beneficiariesThis guidance note considers the trustees powers to make payments and whether the payment made is income or capital.This guidance note is designed to give outline and background for accountants and tax advisers who deal with clients establishing trusts. It is not
Overseas property businesses for companiesOverviewReal estate income is generally taxed where the property is located; the UK tax treaties generally allow the jurisdiction where the land is located to tax income from the land.Therefore, a UK company with overseas property may be subject to tax in
First year allowancesFirst year allowances (FYAs) are available on the following items:鈥irst-year relief on qualifying new main rate plant and machinery (at 100%, which is described by HMRC as 鈥榝ull expensing鈥�) and special rate assets (at 50%) from 1 April 2023 (companies only). These FYAs were