Foreign law matters when a non-UK resident company purchases its own shares

In UK law a company can purchase its own shares from its shareholders. The question then arises about how this should…

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Don’t forget about employee shareholder capital gain tax exemption

Employee shareholder status (ESS) was introduced on 6 April 2013 and was a very generous employee share incentive. Broadly it involved…

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Double trouble when winding down unwanted offshore property structures

It used to be common practice for non-domiciled individuals to hold UK residential property through an offshore company. That way, a…

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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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What exactly is a distribution?

The issue Company distributions are subject to income tax. They have special rates and from 6 April 2022 these rates will…

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31 January 2021 deadline for joining the section 169 Q!

The issue In the 2018/2019 tax year there were a number of transactions where shareholders took advantage of tax deferrals where…

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The tax blunders of Mr Khan

The case In Bostan Khan v HMRC [2020] UKUT 0168, the Upper Tribunal (UT) rejected a taxpayer’s argument that a company purchase of…

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Corbyn’s shares for workers scheme

The issue Jeremy Corbyn has made much of his proposal to introduce a scheme whereby employees will receive 10% of a…

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