Section 77A stamp duty restriction may not be as bad as you think

Many reorganisations involve one company acquiring another company through a share for share exchange. Without a specific relief, stamp duty would…

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Non-UK domiciled beneficiaries may want to ‘raid’ their offshore trusts after 5 April 2025

The temporary repatriation facility (TRF) which was announced on 30 October 2024 was a rare piece of welcome news for non-UK…

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What options are there for AIM shares after the October budget?

Acquiring AIM share portfolios has been a tempting inheritance tax (IHT) planning opportunity for many years. This is because once they…

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Death bed planning for business assets more relevant than ever!

In previous Tax Bites we have discussed the benefits of inter-spouse transfers before the death of one of the spouses. Example…

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How can non-residents access UK pensions tax-free?

The default position for UK pension holders is that any payments will be paid under deduction of UK tax. This will…

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Does it make sense to gift ISAs as an IHT planning strategy

Wealthy families often have significant wealth stored in ISAs which they have built up over their lifetime. Although ISAs are a…

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The new ‘merged’ R & D scheme

For accounting periods on or after 1 April 2024, the R&D scheme for Small and Medium Enterprises (‘SMEs’) and RDEC scheme…

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Who were the Budget’s inheritance tax (IHT) winners?

The 30 October budget was for many people an IHT nightmare. Business and farm owners saw IHT reliefs which had previously…

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Construction work can be subject to stamp duty land tax (SDLT)

It is fairly common for a lease to include an obligation to construct a building on the land which is the…

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Section 455 loophole closed in the Budget

A slightly below the radar announcement was made in the 30 October Budget relating to the closure of a loophole in…

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