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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Use or lose the structures and buildings allowance

The issue A longstanding frustration of businesses is that most capital expenditure on commercial buildings does not benefit from capital allowances…

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Commercial property rebasing rules can be friendly

The issue When gains are made on UK commercial property after 5 April 2019 non-residents (individuals and companies) will be within…

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£1 elections may not take capital allowances off the table

The issue When a property is sold it is quite common for the vendor to insist on a £1 ‘section 198…

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Transfer pricing rules are no longer automatic for tax havens

The issue Generally transfer pricing rules only apply to UK companies which are in small or medium groups by reference to…

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Liquidation loan account woes continued

The last Tax Bite prompted an unprecedented response from liquidator Tax Biters! By way of quick recap, we were discussing a…

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Liquidation loan account woes

The issue HMRC are running a test case to challenge one of the traditional approaches of dealing with an overdrawn directors’…

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When does the transfer (pricing) window open?

The UK’s transfer pricing rules govern the prices charged in transactions between connected parties, the rationale being that in such circumstances…

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The new regime for corporation tax losses

Happy New Tax Year to everyone! We start the first tax bite of 2018/19 on a positive note, with a look…

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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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