Articles by Andrew Marr

Andrew’s expertise lies in bespoke tax planning for owner managed businesses and non-domiciled individuals and he has a successful record of dealing with a number of complex tax enquiries and HMRC negotiations. He also has extensive experience of offshore tax structures which he advises on and implements. He trained in tax with Deloitte in London before moving to the North West and spending nearly seven years at BDO LLP in Manchester before becoming one of the founder partners of Forbes Dawson in early 2012.

+44(0)161 927 3854
andrew@forbesdawson.co.uk

Tax mysteries surrounding distributions from companies limited by guarantee

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?

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

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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Can a company holding alphabet shares benefit from the Substantial Shareholdings Exemption (SSE)?

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?

Last year the Government made the unpopular announcement that Business Property Relief (BPR) would be restricted so that an individual can…

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What were the budget changes to company reconstructions all about?

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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Should Property 118 clients sell up?

We are being asked by quite a few Property 118 (‘P118’) clients to assist with ongoing enquiries. These enquiries all revolve…

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Avoid earnouts when substantial shareholding exemption is available

The substantial shareholding exemption (SSE) is a useful corporation tax relief which exempts corporate sellers from paying corporation tax on the…

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Why the wealthy are flooding back to the UK

You may have looked twice at this title because a truer statement is perhaps that the wealthy are leaving the UK…

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Give away the family home to reduce IHT!

Hopefully quite a few readers have reacted to this title by saying (or thinking!) something like “You can’t get a family…

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