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Loose end

09 June 2005 / John Barnett , Burges Salmon
Issue: 4011 / Categories: Forum & Feedback

Tax rewrite

I recently wrote to HMRC asking whether the wording of ITTOIA 2005, s 397(1) had changed the meaning of TA 1988, s 486 (1). The reference to 'share interest ... payable by a registered industrial and provident society (IPS)' has been replaced by 'payment to a shareholder in such a society'. Potentially this could cover, for example, a payment by one member of the IPS to another.

Confirming that the wording had not changed the interpretation, HMRC gave this explanation:

Tax rewrite

I recently wrote to HMRC asking whether the wording of ITTOIA 2005 s 397(1) had changed the meaning of TA 1988 s 486 (1). The reference to 'share interest ... payable by a registered industrial and provident society (IPS)' has been replaced by 'payment to a shareholder in such a society'. Potentially this could cover for example a payment by one member of the IPS to another.

Confirming that the wording had not changed the interpretation HMRC gave this explanation:

'Unless a point is specifically covered by a Change Note or otherwise dealt with in the Explanatory Notes to ITTOIA 2005 it may be assumed that there is no intended change in meaning between the law as expressed in the old and new section.

We consider that the title of the new section which refers to payments by IPSs the context...

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