HMRC published four sets of draft legislation and explanatory notes alongside last week’s Budget:
The degrouping charge in TCGA 1992 s 179 will be amended with effect from 23 March to ensure that corporation tax cannot be avoided by a series of transactions undertaken within a group prior to the disposal of an asset.
The intangible fixed assets regime is to be amended to ensure that its scope excludes all goodwill and any intangible asset which relates to, derives from or is connected with an oil licence or an interest in an oil licence.
The Finance Bill will include three changes, effective from 24 March, to ‘ensure or put beyond doubt’ that certain Stamp Duty Land Tax avoidance schemes are ineffective.
Changes will be made with effect from 23 March to strengthen the sale of lessor companies legislation, which is intended ‘to impose a charge, at the time of sale, on profits of a lessor company that have been earned but not recognised for tax purposes before it changes ownership’. An appetite for avoidance in this area is ‘still prevalent’, HMRC said in an explanatory note.
HMRC published four sets of draft legislation and explanatory notes alongside last week’s Budget:
The degrouping charge in TCGA 1992 s 179 will be amended with effect from 23 March to ensure that corporation tax cannot be avoided by a series of transactions undertaken within a group prior to the disposal of an asset.
The intangible fixed assets regime is to be amended to ensure that its scope excludes all goodwill and any intangible asset which relates to, derives from or is connected with an oil licence or an interest in an oil licence.
The Finance Bill will include three changes, effective from 24 March, to ‘ensure or put beyond doubt’ that certain Stamp Duty Land Tax avoidance schemes are ineffective.
Changes will be made with effect from 23 March to strengthen the sale of lessor companies legislation, which is intended ‘to impose a charge, at the time of sale, on profits of a lessor company that have been earned but not recognised for tax purposes before it changes ownership’. An appetite for avoidance in this area is ‘still prevalent’, HMRC said in an explanatory note.
