Don’t forget about option holders in private equity deals
21st February 2023
Posted in Articles, Business Asset Disposal Relief by Andrew Marr
The issue Private equity deals often involve the shareholders partially exiting a business by receiving a combination of cash, shares and/or…
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Be careful with discretionary EMI option clauses
10th February 2023
Posted in Articles, Business Asset Disposal Relief by Andrew Marr
The issue Enterprise Management Incentive (‘EMI’) options are a highly tax efficient way for small companies to motivate their employees. They…
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Will we ever know what Zahawi did?
3rd February 2023
Posted in Articles by Andrew Marr
The issue Media has been rife with reports of Nadhim Zahawi’s tax shenanigans. We appear to know the following ‘facts’: 1….
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Paper for paper transactions and ‘lost’ deal costs
30th January 2023
Posted in Articles, Capital Gains Tax by Andrew Marr
The issue It is fairly common for a capital gains tax liability to be deferred under section 135 TCGA 1992 when…
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It pays to return to your rental property
20th January 2023
Posted in Articles, Principal Private Residence Relief by Andrew Marr
The issue It is fairly common for a property owner to rent out a house that was formerly used as their…
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Ascertainable contingent consideration and foreign currency
13th January 2023
Posted in Articles by Andrew Marr
The issue When an asset is disposed of, some consideration may be ascertainable but contingent on a future event. If this…
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Grazing agreements are good for SDLT
6th January 2023
Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
The issue For higher value property transactions, it is generally preferable to be able to apply non-residential rather than residential stamp…
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Tax advantages of a gift to dying spouse
22nd December 2022
Posted in Articles by Andrew Marr
The issue Although I apologise for the miserable title, deathbed tax planning is never going to be a cheerful activity. It…
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How an inter-spouse transfer can avoid residential capital gains tax rates
12th December 2022
Posted in Articles, Capital Gains Tax by Andrew Marr
The issue Residential property gains effectively have an 8% capital gains tax (‘CGT’) surcharge and so it is preferential for land…
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Can stamp duty share for share relief be claimed for multiple companies?
6th December 2022
Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
The issue When a company acquires another company by way of a share for share exchange, the basic rule is that…
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