This guidance applies to companies that hold shares up to 21 April 2009
Whereas CTA09/S524 deals with a specific scheme involving outstanding third party obligations over shares, CTA09/S526 deals with other possible avoidance schemes which attempt to convert interest into some form of return on a share.
The section applies for CT purposes in relation to a company if at any time in an accounting period:
•the company (‘the investing company’) holds a share in another company (‘the issuing company’),
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