CTM34350 - Residence: avoidance transactions: introduction

ICTA88/S765 and ICTA88/S765A

Section 765 is designed to monitor and, if necessary, prevent certain transactions of UK resident corporate bodies or their non-resident subsidiaries by making those transactions unlawful without Treasury consent.

Section 765 subsection (1)(c) and (d) is aimed at transactions in shares and debentures of non- resident subsidiaries that may lead to a loss of UK tax.

In the following guidance the word 'company' means 'body corporate'.