D1.941 Corporate Capital Losses Anti-Avoidance—Schemes Converting Income To Capital

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Commentary

Corporate tax

The following anti-avoidance provision targets schemes seeking to turn an income receipt into capital in order to make use of the relief available for capital losses. The provision applies if HMRC considers that four conditions are satisfied and issue a notice to that effect (see D1.943). The conditions are¹:

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(a)�� a receipt or other amount arises to a company (X) and the receipt arises directly or indirectly in connection with any arrangements²
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(b)�� a chargeable gain accrues to X and it

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E5.607 Corporate members

E4.507S Operation of the charge on securities with artificially enhanced market value

I7.323 APR and successions

D1.8101 Groups of companies

I4.142A Liabilities which are not discharged out of the estate

B2.218 Surplus business accommodation

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