How Incorporation Relief can mess up Business Asset Disposal Relief (BADR)
23rd February 2024 | Posted in Articles, Business Asset Disposal Relief by Andrew Marr
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
9th February 2024 | Posted in Articles, Business Asset Disposal Relief by Forbes Dawson
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?
11th September 2023 | Posted in Articles, Business Asset Disposal Relief by Forbes Dawson
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!
1st September 2023 | Posted in Articles, Business Asset Disposal Relief by Andrew Marr
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?
21st August 2023 | Posted in Articles, Business Asset Disposal Relief, Capital Gains Tax, Private Client, Tax Risk and Investigations by Andrew Marr
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?
30th May 2023 | Posted in Articles, Business Asset Disposal Relief, Capital Gains Tax by Andrew Marr
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
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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Furnished holiday lets and rollover relief
11th August 2022 | Posted in Articles, Business Asset Disposal Relief, Business Property Relief by Tom Minnikin
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?
13th June 2022 | Posted in Articles, Business Asset Disposal Relief, Capital Gains Tax by Andrew Marr
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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