Legislation will be introduced in Finance Bill 2015 amending ITTOIA 2005 to remove the ‘unfair tax advantage’ provided by B share schemes. Helen Gilbey and Sarah Falk (Freshfields Bruckhaus Deringer) analyse the new rules
As promised in the Autumn Statement the draft legislation for Finance Bill 2015 includes measures to remove the ‘unfair tax advantage’ provided by B share schemes. Companies will no longer be able to return cash to their shareholders in a way that offers a choice of income or capital treatment.
These proposals were a surprise. They will disrupt a well-established practice that many will have assumed was blessed by the GAAR guidance.
A number of methods are...
