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
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