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Anti-avoidance simplification
 
Anti-avoidance simplification
 
HMRC has issued a consultation document (see www.lexisurl.com/dmvAG) and impact assessment (see www.lexisurl.com/vl8YS) in relation to proposed changes to the transactions in securities legislation.
 
HMRC has also issued a consultation document (see www.lexisurl.com/788NA) including proposals on how unallowable purposes rules could be simplified.
Trust residence
 
HMRC has issued guidance giving HMRC's view on the application of the residence tests in Taxation of Chargeable Gains Act 1992 s 69(2D) and Income Tax Act 2007 s 475(6) in relation to overseas trust companies — particularly those owned by UK-based groups.
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