What is ‘acceptable’ tax planning for property rich company disposals?

Before 6 April 2019 non-UK resident individuals and companies could generally sell UK companies without having to worry about UK tax…

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Can share cancellation schemes save stamp duty?

In its ‘stamp taxes on shares manual’ HMRC has the following to say on ‘cancellation schemes’: Under this scheme, the Court…

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Can the 30-day bed and breakfasting rule act as a hedge against an increase in capital gains tax?

Before March 1998, ‘bed and breakfasting’ of shares was a generally accepted piece of tax planning. This would work by an…

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SDLT on in specie distributions

There are often cases where it is beneficial to transfer assets from one company to another as a distribution. When property…

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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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Do membership loan schemes work?

It is fairly common for sporting clubs to seek cheap finance from its members for various initiatives (e.g. new tennis courts…

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Create ‘breathing space’ for section 455 charge

Any loans to participators (broadly shareholders) that are outstanding nine months after the year end will be subject to what is…

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Why a cut in the basic rate of tax could hurt landlords

Many landlords have felt somewhat shafted by tax legislation for a while now. The restriction of tax relief on finance costs…

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