On 25 July, following discussions with the CIOT, HMRC updated its Company Taxation Manual (CTM36330 and CTM 36340) in relation to the targeted anti-avoidance rule for distributions on a winding-up introduced by Finance Act 2016.
On 25 July, following discussions with the CIOT, HMRC updated its Company Taxation Manual (CTM36330 and CTM 36340) in relation to the targeted anti-avoidance rule for distributions on a winding-up introduced by Finance Act 2016. The bulk of the changes provide more detail on the main purpose test in condition D.
The CIOT and ATT have also published a short commentary on the changes (see https://bit.ly/2LVGbL6).
On 25 July, following discussions with the CIOT, HMRC updated its Company Taxation Manual (CTM36330 and CTM 36340) in relation to the targeted anti-avoidance rule for distributions on a winding-up introduced by Finance Act 2016.
On 25 July, following discussions with the CIOT, HMRC updated its Company Taxation Manual (CTM36330 and CTM 36340) in relation to the targeted anti-avoidance rule for distributions on a winding-up introduced by Finance Act 2016. The bulk of the changes provide more detail on the main purpose test in condition D.
The CIOT and ATT have also published a short commentary on the changes (see https://bit.ly/2LVGbL6).
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")