Some years ago company A forms, carries out trade X and amasses some retained profits.
About a year ago the trade of company A begins to transition to trade Y and is fully changed over within 3 months. There is a trail of evidence to support this.
Recently company B is formed. Company B carries out trade X. A new company is chosen to limit liabilities and keep accounting separate.
It becomes clear that Trade Y is commercially unsuccessful and thus company A is no longer justified.
If in a few months time company A is closed with ER distribution. Assuming that the companies have same ownership/ board/share structure is this likely to be caught by the transactions in securities (tis) legislation?
I appreciate that tis is somewhat subject to interpretation and do there will be few absolute answers. I'm after opinion and any relevant examples which suggest whether this represents violation of tis. I know that this legislation is undergoing review so let's stick to 'as is' rather than 'to be'.
So whadya think? Is this caught by tis?
Read online that some tax specialists recommended asking hmrc if a transaction falls foul of tis and gaining pre approval- anyone heard about pscs doing this?
About a year ago the trade of company A begins to transition to trade Y and is fully changed over within 3 months. There is a trail of evidence to support this.
Recently company B is formed. Company B carries out trade X. A new company is chosen to limit liabilities and keep accounting separate.
It becomes clear that Trade Y is commercially unsuccessful and thus company A is no longer justified.
If in a few months time company A is closed with ER distribution. Assuming that the companies have same ownership/ board/share structure is this likely to be caught by the transactions in securities (tis) legislation?
I appreciate that tis is somewhat subject to interpretation and do there will be few absolute answers. I'm after opinion and any relevant examples which suggest whether this represents violation of tis. I know that this legislation is undergoing review so let's stick to 'as is' rather than 'to be'.
So whadya think? Is this caught by tis?
Read online that some tax specialists recommended asking hmrc if a transaction falls foul of tis and gaining pre approval- anyone heard about pscs doing this?
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