Make treaty claims on interest payments
27th September 2019
Posted in Articles, Corporation Tax by Andrew Marr
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?
20th September 2019
Posted in Articles by Andrew Marr
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
13th September 2019
Posted in Articles by Forbes Dawson
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!
6th September 2019
Posted in Articles, Capital Gains Tax by Forbes Dawson
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
2nd September 2019
Posted in Articles by Forbes Dawson
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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