Page 32 - P6 Slide Taxation - Lecture Day 6 - Groups, Interest And Practice Questions
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Implications: Normal tax relief
provided for the holding company
• In terms of section 47(5), the holding
company must disregard the disposal or
return of capital for purposes of determining
its taxable income.
• In other words, even though the holding
company is technically disposing of shares as a
result of the liquidation, the holding company
does not have to account for the disposal for
CGT purposes.
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