Attribution of gains to members of non-resident closely controlled companies and transfer of assets abroad - Public Consultation

The ATT invites comments on the consultation that proposes reform of two anti-avoidance provisions: i) the attribution of gains to members of non-resident closely controlled companies and ii) transfer of assets abroad.

Attached is the consultation proposing reforms to two provisions ; TCGA 1992 section 13 and ITA 2007 Part 13 Chapter 2.

Please send comments to atttechnical [at] att.org.uk with 'Attribution of gains' by 8 September 2012

Technical Team

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