Don’t miss out on the flexibility of a section 171A election

For a long time, it has been possible to transfer assets within a group of companies without triggering a chargeable gain….

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Is there a four-year deadline for Transactions in Securities counteraction notices?

Transactions in securities legislation (‘TISL’) is anti-avoidance legislation whereby in certain circumstances HMRC can stop a taxpayer taxing themselves on a…

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Angels and demons and the perils of getting the EIS ‘directors’ rules’ wrong

The Enterprise Investment Scheme (‘EIS’) offers various tax incentives to individuals who invest in start-up companies, including a 30% income tax…

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To have and to hold (over)

With BPR planning now reaching frenzied levels before 5 April 2026, even with the increase in value of the 100% BPR…

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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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The IHT sting of EOT receivables

The Employee Ownership Trust (EOT) tax provisions were enacted in 2014, as a way to encourage long-term employee ownership in businesses,…

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Get the FOTRA out of the UK! – You will want to read this!

Hidden within the Finance Act 2025 was a very helpful change to the tax treatment of UK government securities for inheritance…

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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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Deeds of variation can reduce SDLT!

When a person dies it is possible to amend their will for most practical purposes if this is done within two…

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When inheritance tax can be helpful in a company purchase of own shares

On a purchase of own shares by a company the default position is that any profit over and above the amount…

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