Under the Transactions in Securities (TIS) rules, certain close company distributions are charged to Income Tax instead of under the Capital Gains Tax (CGT) regime. 

Subscribers see Transactions in Securities for your detailed version of this guide.

This is a freeview 'At a glance' guide to the 2016 changes to the Transactions in Securities Legislation (TiS).

Finance Act 2016 amended the TIS rules so that:

1. They have wider application to counteract a tax advantage when a person receives consideration as capital rather than income.

2. A Targeted Anti-Avoidance Rule (TAAR) applies to distributions in respect of share capital in a winding up.

3. The procedure by which HMRC can seek to counteract a tax advantage is simplified.

Clearance Applications

Useful guides on this topic

Transactions in Securities (subscriber guide)
This note examines the rules for an Income Tax advantage from the perspective of shareholders.

TAAR: Distributions on winding up (anti-phoenixing rules)
When does the TAAR apply? Who does it affect? Can you apply for tax clearance? Do the rules affect striking off?

Transactions in securities: Case studies
This guide contains potential case studies for the Transactions in Securities  (TiS) rules. 

Support

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