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Proposed new exemption system for UK and foreign distributions - Part II

Tax Avoidance Schemes

Although a dividend may fall within one of the exempt classes, it would still be taxable if it forms part of one of the following prescribed tax avoidance schemes which has a main purpose of achieving a more than minimal tax advantage.

  • Quasi-preference shares
  • Payments for distributions
  • Payments not on arm’s-length terms
  • Manipulation of controlled company rules
  • Schemes in the nature of loan relationships



Date: 6th March, 2009
Author: Cathy Corns


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