Transactions in Securities - A Road Map with Philip Ridgway - Learn Live

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