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Clarification of ‘change of ownership’
HMRC have published further guidance on the proposed changes to the tax rules on buy-backs of company debt.
For full details, see the online information, which includes clarification of the terms ‘change of ownership’, ‘intrinsic’, and ‘severe financial problems’.
In addition, the department has provided further explanation as to how the new rules will apply to:
- debt restructurings already in progress at the time of the announcement;
- debt restructurings undertaken before the date of the announcement ;
- cases in which the consideration for the repurchased debt is new debt of an equivalent face value; and
- cases involving debt for equity swaps.
