Nigel Doran, tax partner at Macfarlanes, points out that the recent substantial shareholding legislation needs clarifying
Nigel Doran tax partner at Macfarlanes points out that the recent substantial shareholding legislation needs clarifying
It is clear from a paper posted on the Inland Revenue website in June 2002 that the Revenue intended the transfer of a substantial shareholding from one member of a chargeable gains group to another in exchange for shares issued by that other member to fall within the 'no disposal' provisions of TCGA 1992 s 127 (as applied by s 135) rather than the substantial shareholding exemption or the 'no gain no loss' provisions of TCGA 1992 s 171(1). However the substantial shareholdings legislation does not make this at all clear. Rather to achieve this...
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Nigel Doran, tax partner at Macfarlanes, points out that the recent substantial shareholding legislation needs clarifying
Nigel Doran tax partner at Macfarlanes points out that the recent substantial shareholding legislation needs clarifying
It is clear from a paper posted on the Inland Revenue website in June 2002 that the Revenue intended the transfer of a substantial shareholding from one member of a chargeable gains group to another in exchange for shares issued by that other member to fall within the 'no disposal' provisions of TCGA 1992 s 127 (as applied by s 135) rather than the substantial shareholding exemption or the 'no gain no loss' provisions of TCGA 1992 s 171(1). However the substantial shareholdings legislation does not make this at all clear. Rather to achieve this...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
