Anti-avoidance provisions

Abolitions proposed

Charge to tax

Double charges, avoidance

Exceptions from the charge



Chargeable gains

Consideration chargeable to tax on income

Exclusion of expenditure, tax on income

Controlled foreign companies

Income tax

Charge to tax

Double taxation, avoidance of

Income charged

Person liable

Shares, exception for returns from

Loan relationships

Excluded shares

Exclusion where arrangement has no tax avoidance motive

Exclusion where return otherwise taxable


Regarded as profit from

Shares accounted for as liabilities

Sale and repurchase of securities