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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Market value in company purchase of own share transactions
29th November 2022 | Posted in Articles by Forbes Dawson
The issue When a company purchases its own shares then the default position is that proceeds will be taxed as a…
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