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HMRC has indicated a change of view in its approach to the availability of TCGA 1992 section 162 relief where a ‘mixed partnership' (LLP) ie one including both individuals and a corporate member incorporates the partnership business into the existing corporate member. In correspondence with the CIOT in 2014, HMRC confirmed that, subject to all the other conditions being satisfied, they would accept that TCGA 1992 section 162 can apply to the individual members where an LLP transfers its business to the corporate member in exchange for shares in the corporate member.

As announced at Autumn Statement 20151, the government has been considering possible legislation to amend the changes made by Finance Act 2015 to Entrepreneurs’ Relief, in order to support businesses by ensuring that the relief remains available on certain genuine commercial transactions.

A significant change to HMRC’s guidance at RDRM33170 was announced in HMRC’s ‘What’s New’ on 4 August 

Links to CIOT papers and external information on and relevant to the Calman Commission proposals for taxation in Scotland.

A technical paper prepared for members by the CIOT

We have provided the draft Finance Bill 2015 clauses along with related documents below in Adobe (PDF) format.

Document on FATCA and trusts posted December 2014.