CTM34380 - Residence: avoidance transactions: general consent

ICTA88/S765 and ICTA88/S765A

Treasury consent may be general or special (Section 765 (4)). The general consents in force until 15 March 1988 are reproduced at CTM34480. These related to transactions under all four subheads of subsection (1). They are still relevant in considering whether transactions before 15 March 1988 were lawful and in particular whether UK incorporated companies migrated under the protection of the first general consent.

New general consents relating only to transactions within subsection (1)(c) and (d) apply from 15 March 1988 and are reproduced at CTM34470. The consents are intended to cover types of transactions that are less likely than others to lead to a loss of tax.