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HMRC internal manual

Company Taxation Manual

Company taxation manual: recent changes

Below are details of the amendments that were published on 8 April 2010 (see the update index for all updates).

Section Details of update  
CTM01750 & CTM03510  Added note to guidance relating to ‘oil tax ring fence regimes’  
CTM47500- CTM47596  New guidance which sets out the detail of a new optional tax framework for investment trusts investing in interest bearing assets.  
  Trading v Investment - The changes below explain new rules that prevent defined financial transactions carried out by authorised investment funds (AIFs) from being characterised as trading transactions for tax purposes and give AIFs certainty that gains on the realisation of certain types of investments, which would not be chargeable gains, will not be re’characterised as profits arising from a trade and taxable as income.  
CTM48280-CTM48295  New section at ‘taxation of funds’.  
CTM48530-CTM48540  New section at ‘taxation of participants within the charge to CT’.  
CTM48570-CTM48580  New section at ‘taxation of participants within the charge to IT’.  
CTM48150-CTM48175  New guidance on Genuine diveristy of ownership (GDO) - The GDO aims to prevent small groups of investors from taking advantage of the tax treatment available to investors in widely pooled schemes using closely held arrangements that may in reality be for the benefit of a tightly constricted group.  
CTM48900-CTM48972  New section on ‘tax elected funds’. Tax elected funds is a new tax regime for authorised investment funds which took effect from 1 September 2009.