Make treaty claims on interest payments

The issue UK companies often have interest bearing loans from offshore entities. Although as a default position withholding tax is accountable…

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Will the loan charge be scrapped?

The issue Outstanding loans made to individuals from EBTs, EFRBS and other similar ‘disguised remuneration’ arrangements on 5 April 2019 became…

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Potter case and non-trading activities for Entrepreneurs’ Relief purposes

The issue A key requirement for Entrepreneurs’ Relief (ER) to be available in respect of a share disposal is that the…

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Skinner’s an Entrepreneurs’ Relief winner!

Background This week we report upon a welcome defeat for HMRC in the case of The Quentin Skinner 2005 Settlement L…

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The 5 April 2019 loan charge and actions required by 1 October 2019

Breakdown In 2017 the Government legislated to introduce a charge on outstanding loans from EBTs, EFRBS and other ‘disguised remuneration’ schemes. …

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