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Chapter 6: Company purchase of own shares

Tax Planning: 2021/22

Edited by:
Mark McLaughlin
Publisher:
Bloomsbury Professional
Edition:
2021/22 edition
Publication Date:
September 2021
Law Stated At:
July 2021
Introduction Meeting the conditions Company status Purpose of the payment Statement of Practice 2/82 Retaining an interest in the company Allum v Marsh Factors to consider Residence of vendor Period of ownership The ‘substantial reduction’ test The ‘no continuing connection’ test Practical issues Income or capital? Status of the shares Company status Clearance applications to HMRC Breaching the conditions for capital treatment Application for clearance under CTA 2010, s 1044 ...

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