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In this episode of The UK Tax Podcast, John Kavanagh, Chartered Tax Adviser, examines the risks of distributions in a liquidation being taxed as income rather than capital under the Targeted Anti-Avoidance Rule (TAAR). With no binding case law and limited guidance from HMRC, this is a highly uncertain area, particularly where individuals resume similar business activities after a winding up. John explains how the TAAR operates, the importance of Conditions C and D, and why securing Business Asset Disposal Relief (BADR) can be far from straightforward. Essential listening for advisers and business owners considering company liquidation.
By John Kavanagh CTA ATT FRSASend us a text
In this episode of The UK Tax Podcast, John Kavanagh, Chartered Tax Adviser, examines the risks of distributions in a liquidation being taxed as income rather than capital under the Targeted Anti-Avoidance Rule (TAAR). With no binding case law and limited guidance from HMRC, this is a highly uncertain area, particularly where individuals resume similar business activities after a winding up. John explains how the TAAR operates, the importance of Conditions C and D, and why securing Business Asset Disposal Relief (BADR) can be far from straightforward. Essential listening for advisers and business owners considering company liquidation.