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UK Tax Podcast · Mar 5, 2025 · 7 min

Tax Risks of Liquidation Distributions – Navigating the TAAR

Send us Fan Mail In this episode of The UK Tax Podcast, John Kavanagh, Chartered Tax Adviser, examines the risks of distributions in a liquidation being taxed as income rather than capital under the Targeted Anti-Avoidance Rule (TAAR). With no binding case law and limited guidance from HMRC, this is a highly uncertain area, particularly where individuals resume similar business activities after a winding up. John explains how the TAAR operates, the importance of Conditions C and D, and why securing Business Asset Disposal Relief (BADR) can be far from straightforward. Essential listening for advisers and business owners considering company liquidation.

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Send us Fan Mail

In this episode of The UK Tax Podcast, John Kavanagh, Chartered Tax Adviser, examines the risks of distributions in a liquidation being taxed as income rather than capital under the Targeted Anti-Avoidance Rule (TAAR). With no binding case law and limited guidance from HMRC, this is a highly uncertain area, particularly where individuals resume similar business activities after a winding up. John explains how the TAAR operates, the importance of Conditions C and D, and why securing Business Asset Disposal Relief (BADR) can be far from straightforward. Essential listening for advisers and business owners considering company liquidation.

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