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Transfer of Assets Abroad and the quasi-transferor
TRANSFER OF ASSETS ABROAD AND THE QUASI-TRANSFEROR This article considers the position of those whom HMRC regard as quasi-transferor for the purposes of the T Transfer of Assets Abroad (“TOAA”) legislation. This legislation (and HMRC’s interpretation of it) is potentially draconian in its effects, so it will almost always need […]
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QROPS – A guide
QROPS – A BRIEF GUIDE 1. What is a QROPS? QROPS stands for “Qualifying Registered Overseas Pension Scheme. A QROPS is an overseas pension scheme which meets a number of criteria set out in legislation and regulations, the most important of which are that it: • is regulated as a […]
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Follower Notice penalties – the Corrado case
Follower Notice penalties – The Corrado Case The recently reported Corrado case has confirmed the validity of our approach to Follower Notice Penalties. In our previous blog post on the subject of Follower Notice Penalties, we noted that one of the most invidious (and potentially expensive) aspects of the Follower […]
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Loan relationships, connected companies and impairment losses
Loan relationships: connected companies and impairment losses We are frequently asked to advise on the loan relationships tax position where loans between connected companies have become irrecoverable. In most cases, there is a “tax nothing”; neither impairment losses nor release debits need to be brought into account in the respective […]
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Growth shares – the basics
Growth shares – the basics What are growth shares? Growth shares enable a new shareholder (whether an employee or not) to participate in the future growth of a company but do not confer an interest in the company’s existing assets. Share incentives structured in this way are generally far more […]
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The myth of the long-term tax strategy
The myth of the long term tax strategy I am often asked by accountants to help advise their clients on long-term tax strategy. I’ll be honest – this gives me a problem. Mythical beast And it’s because the long-term tax strategy is something of a mythical beast – or at […]
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CEST, MOO and Status Anxiety
Status Anxiety A few years ago, I read a book with this title by the philosopher Alain de Botton, wherein he described status anxiety as the constant fear of being perceived by society as unsuccessful – a very 21st century and decidedly first world problem. In the tax and employment […]
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Using a small self-administered pension scheme (SSAS) to own business premises
USING A SMALL SELF-ADMINISTERED PENSION SCHEME (SSAS) TO OWN BUSINESS PREMISES What is a SSAS? A SSAS is an employer-sponsored pension scheme (established as a trust) with fewer than 12 members, usually restricted to senior employees or directors of a limited company. The members of the scheme will also be […]
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The Post-Incorporation Directors Loan Account – A Potential IHT problem?
THE POST-INCORPORATION DIRECTORS LOAN ACCOUNT – A POTENTIAL IHT PROBLEM? The Incorporation Boom In the late 2000s and early 2010s, incorporation was for many sole traders and partnerships running businesses, something of a “no-brainer”. There were numerous reasons for this. Firstly, from the 2008/9 tax year onwards, capital gains tax […]
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Non-resident CGT on UK Property – the right measure at the wrong time?
Non-resident CGT on UK Property – the right measure at the wrong time? In over 30 years as a tax adviser, I find it difficult to think of a more fundamental change of principle in the UK tax system than the imposition of UK tax on disposals by non-residents of […]
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