Entrepreneurs’ relief withdrawn for alphabet shares?

The issue Before 29 October 2018 (budget day) it was fairly common knowledge that various conditions needed to be met for…

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Banking Entrepreneurs’ Relief on a dilution

The issue In Spring 2018, the Government published a consultation setting out its proposal for allowing shareholders to retain the benefit…

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Does home working affect Principal Private Residence Relief (PPR)?

Background There seems to be something of a ‘tax myth’ about the capital gains tax position if a home worker sells…

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When will HMRC pull their finger out on ‘phoenixing rules’?

On 25 July HMRC amended their guidance on the much maligned targeted anti-avoidance rule (or ‘TAAR’). When I heard this I…

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Company share purchase connection trap

Company purchase of own shares As anyone who has dipped their toes into the waters of tax will know, a purchase…

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The new improved Substantial Shareholdings Exemption

The Substantial Shareholdings Exemption (‘SSE’) was introduced in 2002 as part of the government’s drive to make the UK a better…

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Take care when mixing EIS with EMI

EMI schemes Incentivising key employees by giving them an equity interest in the company not only makes sense from a motivational…

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Watch out for long warranty periods in deals!

The issue Nearly all business sales will include warranties. A warranty broadly means that a seller states that something is or…

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Capital allowances on websites

The issue Website costs can be significant and are often capitalised in a company’s accounts. Traditionally HMRC has viewed such capital…

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An Entrepreneurs’ Relief muddle … resolved

Conflicting tax cases In May we highlighted two Tribunal decisions which looked into the issue of whether certain types of share…

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