These provisions apply for income tax purposes. For details of the corporation tax regime see ·¡1.1440–E1.1444.
As previously noted, a negative filter is one intended to take a person outside the scope of the legislation. As well as being helpful to taxpayers, this is a resource saving for HMRC, as they should not have to review so many clearance applications. The negative filter in the current income tax rules for transactions in securities is the 'fundamental
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