Prior to December's Pre-Budget Report HMRC attention had focused on what was perceived to be an unfair use of capital allowances where a company changed hands. Legislation has now been introduced to address this perceived tax avoidance. The legislation is in FA 2010 s 26 and Sch 4 which insert into CAA 2001 a new Chapter 16A (ss 212A–212S).
The new legislation targets the perceived avoidance where a company is sold (or its ownership otherwise changes) at a time when the tax written-down value of its plant and machinery exceeds the balance sheet value of that same plant and machinery. Importantly however the legislation only targets those instances where the main purpose or one of the main purposes of the change in ownership was the obtaining of a tax advantage.
Basically what HMRC...
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Prior to December's Pre-Budget Report HMRC attention had focused on what was perceived to be an unfair use of capital allowances where a company changed hands. Legislation has now been introduced to address this perceived tax avoidance. The legislation is in FA 2010 s 26 and Sch 4 which insert into CAA 2001 a new Chapter 16A (ss 212A–212S).
The new legislation targets the perceived avoidance where a company is sold (or its ownership otherwise changes) at a time when the tax written-down value of its plant and machinery exceeds the balance sheet value of that same plant and machinery. Importantly however the legislation only targets those instances where the main purpose or one of the main purposes of the change in ownership was the obtaining of a tax advantage.
Basically what HMRC...
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