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13 June 2017
Issue: 4603 / Categories: Forum & Feedback

Correspondence from readers on topical subjects.

More feedback on buybacks

I have read Sara Cohen’s recent article (see ‘Buybacks revisited’  11 May 2017 page 10) and further comments (‘Feedback’ 1 June 2017 page 20). Originally I thought her article ‘Multiple attraction’ (13 October 2011 page 14) said all that was needed. However she has pointed to the November 2016 edition of Tolley’s Practical Tax Newsletter from which it seems that HMRC is still trying to prevent a single exchange multiple completion share buyback being effective.

In general I still agree with Sara that there should be a disposal at the time of the original single exchange multiple completion contract. However I am less sure about the reasoning given in the article. I agree that TCGA 1992 s 22 cannot apply and for the reasons given in the 1 June issue. However I do not...

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