What is now ICTA88/S491 was introduced to reverse the effect of
the decision in Brogan v Stafford Coal & Iron Company Ltd
[1963] 41TC305 - see
BIM24550.
The following guidance covers:
| BIM24605 | Distributions may be taxable on first principles |
| BIM24610 | To what does ICTA88/S491 apply? |
| BIM24615 | What is taxed? |
| BIM24620 | Taxable as receipt of trade or post cessation receipt |
| BIM24625 | Allowable deductions and reliefs where recipient’s trade permanently discontinued |
| BIM24630 | What are capital assets for ICTA88/S491? |