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Euromoney Institutional Investor plc v HMRC, the FTT  held that the share for share exchange treatment in section 135 TCGA 1992 applied despite the presence of a tax avoidance purpose. Euromoney sold its shares in a subsidiary company to a third party buyer. The consideration was originally intended to be satisfied by ordinary shares and cash. However, upon the advice of the company’s tax director, the cash portion of the consideration was substituted for preference shares so as to allow the transaction to benefit from share for share exchange treatment under section 135 TCGA 1992 (and thus prevent an immediate tax charge). Following a 12 month ownership period, the preference shares could then be redeemed with the benefit of the substantial shareholding exemption (SSE) applying to the redemption given the holding of the ordinary shares so that the disposal of the preference shares would be exempt from corporation tax on chargeable gains.

United statesUnited kingdomCzech republicLady ardenOrganisation for economicSupreme courtOffice of the united states trade representativeProskauer roseM group holdings ltdHouse of the courtExchange of informationModel tax convention on incomeParliament to royal assentBalhousie holdings ltdGlobal forum on transparencyPublic bill committee