How Incorporation Relief can mess up Business Asset Disposal Relief (BADR)

Section 162 TCGA 1992 is a handy piece of legislation which allows business owners to incorporate without triggering an immediate capital…

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Section 169Q elections when there’s no more BADR

The heady days of a £10m lifetime Entrepreneurs’ Relief allowance are now a distant memory. This was reduced to £1m in…

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Use preference shares to ‘turn on’ BADR for goodwill on incorporation?

Before changes in the 2015 Finance Act, it was fairly common for sole traders and partnerships to sell their trade and…

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Don’t forget about the fiddly bits of holdover relief!

Apart from assets which are transferred between spouses and civil partners, the default position for capital gains tax purposes is that…

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Is it OK to breach transactions in securities legislation?

Transactions in securities legislation (TISL) has been around for a long time and the legislation has gone through some changes, most…

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What is the deadline for transactions in securities legislation?

The issue Transactions in securities legislation (TISL) has been around for a while. In very broad terms it allows HMRC to…

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Don’t forget about option holders in private equity deals

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

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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Furnished holiday lets and rollover relief

The issue Furnished holiday lets (‘FHLs’) are treated more generously for tax purposes than normal residential buy-to-let properties. Specifically, a FHL…

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Convert a property to a furnished holiday let?

The issue Normally a residential rental property would be subject to a 28% capital gains tax (CGT) rate on its disposal….

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