Uncertainty around whether interest has a UK source

There is tax legislation (ITA 2007 section 874) which dictates that tax needs to be withheld from certain interest payments (generally…

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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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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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How married couples can take advantage of the ‘50%:50%’ rental property rule

It is fairly common for one spouse (or civil partner) to want to share the taxation of rental income with their…

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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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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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Is Labour’s rumoured attack on partnerships justified?

According to reports in this week’s media, Rachel Reeves is planning to hit partnerships with higher tax charges at next month’s…

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Do knee-jerk lump sum pension withdrawals make sense?

Once again we are in the season of ‘Budget madness’. This season will run all the way until 26 November 2025…

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Take out life insurance to mitigate inheritance tax (IHT) on pensions

From 6 April 2027 (if nothing changes) pension funds will be subject to 40% inheritance tax (IHT). Previously pensions were generally…

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How the new merged R&D scheme can lead to late payment charges

By now, most companies are aware of the new merged R&D scheme (for more information on this see our previous tax…

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