Course description
Delve into the intricacies of securities legislation in this 3-hour virtual session with Philip Ridgway from Temple Tax Chambers. Recent shifts in HMRC's clearance approach and a surge in counteraction notices have brought this topic to the forefront.
This interactive course aims to demystify the legislation and caselaw, providing clarity on its applicability and consequences.
Discover the legislative history, conditions for application, tax advantages, distribution limitations, and the motive test. Explore the nuances of clearance, counteraction, and the appeals process, ensuring you're well-equipped to navigate this complex legal landscape.
Upcoming start dates
Outcome / Qualification etc.
Training Course Content
Introduction
Even the simplest of transactions can give rise to potential issues with transactions in securities legislation. There has recently been a renewed focus on the rules as HMRC appear to have altered their stance on giving clearance and a raft of counteraction notices have been issued for transactions undertaken in early 2016.
This 3 hour virtual classroom session, presented by Philip Ridgway of Temple Tax Chambers, seeks to demystify the legislation and caselaw and to provide a road map as to when the legislation will apply and the consequences of it doing so.
What You Will Learn
This live and interactive course will cover the following:
- Setting the scene
- A brief history of the Transactions in securities rules
- The view from 30,000 feet and the mischief aimed at
- Looking at the legislation
- Conditions necessary for the rules to apply
- Relevant consideration
- Tax advantage
- The distribution limitation
- What are: ‘profits available for distribution’?
- If you’re looking for a way out
- Main purpose not the avoidance of tax - aka the motive test
- Fundamental change of ownership
- Looking at the cases
- Some common transactions - and the attendant issues
- Share Exchanges
- Purchase of own shares
- Management buy-outs
- Reductions of capital
- Sales to an EOT
- Clearance
- Counteraction
- Appeals
Expenses
MBL Seminars Limited
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