Draft anti-avoidance legislation and Explanatory Notes

Double tax relief - Unauthorised Unit Trusts (‘UUTs’) and Manufactured Overseas Dividends (‘MODs’)

A Written Statement by the Financial Secretary to the Treasury, Stephen Timms, was published on the HMRC website on 21 October. It announced changes to be made to legislation to counter several tax avoidance schemes that have been notified to HM Revenue & Customs (HMRC).

Written ministerial statement of 21 October
HMRC technical note (PDF 34K), also published on 21 October

3 November 2009

Draft legislation, together with Explanatory Notes, is published today regarding two of the measures concerned. They relate to UUTs and MODs.

Comments are invited by 31 December 2009 – please see the two documents below for further details:

The documents relating to the UUTs measure M0250 (PDF 220K)(5 November: Note - this link will direct you to an amended version of the document published on 3 November; the amendment corrects an error contained within the draft legislation in the original document)

The documents relating to the MODs measure M251 (PDF 101K)