Tax mysteries surrounding distributions from companies limited by guarantee
30th January 2026
Posted in Articles by Andrew Marr
Companies which are limited by guarantee do not have shareholders and instead have members who act as guarantors. These kinds of…
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How are PETs taxed when value falls?
23rd January 2026
Posted in Articles by Andrew Marr
A potentially exempt transfer (PET) is a gift that will ‘potentially’ be outside a donor’s estate for inheritance tax (IHT) purposes….
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Uncertainty around whether interest has a UK source
16th January 2026
Posted in Articles by Andrew Marr
There is tax legislation (ITA 2007 section 874) which dictates that tax needs to be withheld from certain interest payments (generally…
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How loans can deny the Substantial Shareholding Exemption (SSE)
9th January 2026
Posted in Articles by Forbes Dawson
The Substantial Shareholding Exemption (SSE) should generally apply to disposals by companies of trading subsidiaries if the shareholding is at least…
Read moreSignificant relaxation of Inheritance Tax (‘IHT’) changes for BPR and APR
6th January 2026
Posted in Articles by Forbes Dawson
You may be aware that significant changes to Business Property Relief and Agricultural Property Relief were announced in the October 2024…
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Can a company holding alphabet shares benefit from the Substantial Shareholdings Exemption (SSE)?
22nd December 2025
Posted in Articles, Business Tax by Andrew Marr
The Substantial Shareholding Exemption (SSE) can be a valuable relief when a company sells shares in a trading company (which I will refer to as “target”). If certain conditions are met, then any gain in respect of the share disposal is not subject to tax. Otherwise, it would be taxable at 25%, so the stakes are high.
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Have inter-spouse transfers of business property been a waste of time?
5th December 2025
Posted in Articles, IHT by Andrew Marr
Last year the Government made the unpopular announcement that Business Property Relief (BPR) would be restricted so that an individual can…
Read moreTax Table 2026
2nd December 2025
Posted in Articles by Forbes Dawson
Following the recent Budget please follow this link to our table summarising the tax rates for the 2026/27 tax year. As…
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What were the budget changes to company reconstructions all about?
28th November 2025
Posted in Articles by Andrew Marr
On Wednesday, many of you may not have noticed a few changes to anti-avoidance rules relating to company reconstructions, but they…
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Autumn Budget 2025
26th November 2025
Posted in Articles by Forbes Dawson
Not many surprises emerged from a budget whose detail was relentlessly leaked over the preceding days before being accidentally released in…
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