WebIn addition, HMRC will not generally deal with advance clearance applications on certain tax issues, including the following: The ‘settlements’ income tax anti-avoidance rules (in ITTOIA 2005, pt 5, Ch 5); Trust deeds or settlements (i.e. executing non-charitable ones); WebJul 11, 2024 · Provided that all of the requirements of section 135 of the Taxation of Chargeable Gains Act 1992 (TCGA 1992) are met in relation to the sale of the shares to the employee-ownership trust (EOT) trustee, this should have the effect that there is no disposal for capital gains tax (CGT) purposes at the point that the shares are initially sold to the …
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WebDec 1, 2007 · This rule is subject to Revenue & Customs being satisfied that the loan note has been issued for genuine commercial reasons and not mainly to avoid tax (s137 TCGA 1992). The vendor would normally apply for a s138 TCGA 1992 clearance to seek advance confirmation of this point from the Revenue. Web138 Procedure for clearance in advance. (1) Section 137 shall not affect the operation of section 135 or 136 in any case where, before the issue is made, the Board have, on the application of either company mentioned in section 137 (1), notified the company that the Board are satisfied that the exchange, reconstruction or amalgamation will be ... emitha font download free
CG52631 - Share exchange: anti-avoidance: clearance …
WebTCGA92/S138 allows either of these companies to apply to the Board for confirmation that the anti-avoidance provisions of TCGA92/S137 will not prevent TCGA92/S135 from … Web138 Procedure for clearance in advance. 138 (1) Section 137 shall not affect the operation of section 135 or 136, in any case where, before the issue is made, the Board have, on the … WebTAXATION OF CHARGEABLE GAINS ACT 1992 PART IV – SHARES, SECURITIES, OPTIONS ETC. (s. 104) Chapter II – Reorganisation of Share Capital, Conversion of Securities etc. (s. 126) COMPANY RECONSTRUCTIONS (s. 135) 139 Reconstruction involving transfer of business 139 Reconstruction involving transfer of business Related Commentary Related … emitheflamingo