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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How 10 years fly by with EMI

Enterprise Management Incentive (‘EMI’) schemes are specifically designed for private trading companies who wish to recruit and retain key employees. They…

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Tax mysteries surrounding distributions from companies limited by guarantee

Companies which are limited by guarantee do not have shareholders and instead have members who act as guarantors. These kinds of…

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How are PETs taxed when value falls?

A potentially exempt transfer (PET) is a gift that will ‘potentially’ be outside a donor’s estate for inheritance tax (IHT) purposes….

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How loans can deny the Substantial Shareholding Exemption (SSE)

The Substantial Shareholding Exemption (SSE) should generally apply to disposals by companies of trading subsidiaries if the shareholding is at least…

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Can a company holding alphabet shares benefit from the Substantial Shareholdings Exemption (SSE)?

The Substantial Shareholding Exemption (SSE) can be a valuable relief when a company sells shares in a trading company (which I will refer to as “target”). If certain conditions are met, then any gain in respect of the share disposal is not subject to tax. Otherwise, it would be taxable at 25%, so the stakes are high.

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Have inter-spouse transfers of business property been a waste of time?

Last year the Government made the unpopular announcement that Business Property Relief (BPR) would be restricted so that an individual can…

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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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