E1.1430 Administrative provisions for transactions in securities
The transactions in securities (TiS) legislation specifically provides for counteraction notices to be issued by an officer of HMRC. The administration of the legislation is dealt with by the Clearance and Counteraction Team in the Anti-Avoidance Group1.
In the case of a person who has died, an HMRC officer may issue notices and notifications (see below) to their personal representatives, who have the same obligations and rights as the deceased taxpayer would have had as regards supplying information, the making of a statutory declaration and appeals2.
Interaction with self-assessment
As counteraction under the TiS anti-avoidance provisions requires a notice to be issued by the Board of HMRC, liability (or potential liability) under the provisions cannot be a matter for self-assessment. This was confirmed in a Tax Bulletin3, which states explicitly that there is no requirement to self-assess section 703 liabilities (and, by extension, liabilities under CTA 2010, Pt 15 or under ITA 2007, ss 682–713 (Pt 13, Ch 1). Taxpayers are invited,
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