Failed PETS to profligate kids can still be IHT-efficient!
2nd May 2025
Posted in Articles by Andrew Marr
Perhaps the most common inheritance tax (IHT) saving strategy is for a donor to make a gift to a donee and…
Read more
How to tax options and non-refundable deposits
21st March 2025
Posted in Articles by Andrew Marr
There seems to be quite a bit of confusion around the taxation of options fees and how they relate to the…
Read more
Section 77A stamp duty restriction may not be as bad as you think
14th February 2025
Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
Many reorganisations involve one company acquiring another company through a share for share exchange. Without a specific relief, stamp duty would…
Read more
Construction work can be subject to stamp duty land tax (SDLT)
13th December 2024
Posted in Articles, Stamp Duty Land Tax by Andrew Marr
It is fairly common for a lease to include an obligation to construct a building on the land which is the…
Read more
What is ‘acceptable’ tax planning for property rich company disposals?
18th October 2024
Posted in Articles by Andrew Marr
Before 6 April 2019 non-UK resident individuals and companies could generally sell UK companies without having to worry about UK tax…
Read more
Can share cancellation schemes save stamp duty?
11th October 2024
Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
In its ‘stamp taxes on shares manual’ HMRC has the following to say on ‘cancellation schemes’: Under this scheme, the Court…
Read more
Can the 30-day bed and breakfasting rule act as a hedge against an increase in capital gains tax?
1st October 2024
Posted in Articles by Andrew Marr
Before March 1998, ‘bed and breakfasting’ of shares was a generally accepted piece of tax planning. This would work by an…
Read more
SDLT on in specie distributions
26th June 2024
Posted in Articles, Stamp Duty, Stamp Duty Land Tax by Andrew Marr
There are often cases where it is beneficial to transfer assets from one company to another as a distribution. When property…
Read more
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…
Read more
Do membership loan schemes work?
2nd February 2024
Posted in Articles by Andrew Marr
It is fairly common for sporting clubs to seek cheap finance from its members for various initiatives (e.g. new tennis courts…
Read more
