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Transactions in securities (TiS)—general

E1.1401 Transactions in securities (TiS)—overview

[For additional key resources on this topic see 'Transactions in securities—related content' below.]

The two sets of transactions in securities (TiS) legislation now largely target tax avoidance arrangements which aim to substitute income receipts with capital receipts. There are separate transactions in securities provisions governing income tax advantages (E1.1417–E1.1419) and corporation tax advantages (E1.1440–E1.1444).

Given that corporation tax is currently charged at the same rate for both income and capital gains, and that most dividend income received by companies is not taxable, the corporation tax rules are now largely not applicable. They have not, however, been repealed.

The TiS income tax rules are contained in ITA 2007, ss 682–713 (Pt 13, Ch 1).

The TiS corporation tax rules are set out in CTA 2010, ss 731–751 (Pt 15).

Where a person obtains a tax advantage and the necessary conditions are satisfied, HMRC have the power to counteract that advantage by making such adjustments as