The issue UK companies often have interest bearing loans from offshore entities. Although as a default position withholding tax is accountable…Read more
The issue Outstanding loans made to individuals from EBTs, EFRBS and other similar ‘disguised remuneration’ arrangements on 5 April 2019 became…Read more
The issue A key requirement for Entrepreneurs’ Relief (ER) to be available in respect of a share disposal is that the…Read more
Background This week we report upon a welcome defeat for HMRC in the case of The Quentin Skinner 2005 Settlement L…Read more
Breakdown In 2017 the Government legislated to introduce a charge on outstanding loans from EBTs, EFRBS and other ‘disguised remuneration’ schemes. …Read more
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