Child’s occupation of ATED property can lead to a nasty surprise
14th June 2024 | Posted in Articles by Marianne Cain
The Annual Tax on Enveloped Dwellings (‘ATED’) is a yearly charge applying to high-value residential property which is held by a…
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Be very careful when transferring property loans in a section 162 incorporation
7th June 2024 | Posted in Articles by Andrew Marr
Property business incorporations have been quite topical recently. The tax blogger Dan Neidle has attacked various mass marketed planning strategies in…
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Abolition of Multiple Dwellings Relief does not prevent reclaims being made
31st May 2024 | Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
On 6 March 2024 the Chancellor announced that Multiple Dwellings Relief (MDR) was to be abolished from 1 June 2024 (unless…
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Foreign law matters when a non-UK resident company purchases its own shares
24th May 2024 | Posted in Articles by Andrew Marr
In UK law a company can purchase its own shares from its shareholders. The question then arises about how this should…
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Don’t forget about employee shareholder capital gain tax exemption
17th May 2024 | Posted in Articles by Andrew Marr
Employee shareholder status (ESS) was introduced on 6 April 2013 and was a very generous employee share incentive. Broadly it involved…
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Can you utilise your pensions annual allowance for a tax year where you have no earnings?
10th May 2024 | Posted in Articles by Andrew Marr
Most people are aware of the annual allowance which exists for pension contributions. In years up to 2022/23 the annual allowance…
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Take a cheap mortgage from your company!
3rd May 2024 | Posted in Articles by Andrew Marr
Perhaps surprisingly, HMRC has announced that the official rate of interest (ORI) for employee loans will remain at only 2.25% for…
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Spread bet your way to a tax-free remittance?
30th April 2024 | Posted in Articles by Andrew Marr
The remittance basis of taxation can apply to non-UK domiciled individuals. This means that in certain tax years they could escape…
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Business Asset Disposal Relief (‘BADR’) for 4.9% shareholdings?
19th April 2024 | Posted in Articles by Andrew Marr
When shareholders seek to claim the special 10% BADR capital gains tax rate it is a fairly well-established principle that they…
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The stamp duty land tax (SDLT) risk of de-enveloping property companies
12th April 2024 | Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
FA 2003 section 75A is the main piece of SDLT anti-avoidance legislation that HMRC has at its disposal to attack certain…
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