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Sale of lessor companies and tonnage tax: draft legislation

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Proposed changes to the sale of lessor companies rules will apply from 21 March 2012 to ‘prevent a risk of forestalling’. The FA 2006 provisions counter ‘a risk that tax would not be paid on the profits of a leasing business following a sale of the company’.

The draft legislation addresses a similar risk, HMRC said in a draft explanatory note, that arises where ‘a lessor company becomes subject to the tonnage tax rules so that its profits cease to be calculated by reference to the normal corporation tax rules’.

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