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Business Asset Disposal Relief – Traps for the unwary
BADR traps for the unwary Business asset disposal relief may not be the most complicated CGT relief there is but it still sets traps here and there. Our professional clients, in particular, discuss BADR with their clients all the time but the points outlined in this article may still sometimes […]
Read MoreQuoted Eurobonds – source of interest
Quoted Eurobonds – source of interest Quoted Eurobonds are often used in structuring debt where offshore entities provide funds for UK activities, e.g., property investment or trading. Conveniently, there is an exemption from withholding tax on the interest paid on Quoted Eurobonds so the overseas investor will not usually be […]
Read MoreTo QCB or not to QCB
To QCB or not to QCB You – or perhaps your client – are selling a trading company. The buyer either cannot afford to pay cash in full or does not want to. The buyer is prepared to offer loan notes to be redeemed at some point in the future. […]
Read MoreTransferring a Property Rental Business to a Limited Company
Transferring a Property Rental Business to a Limited Company Recorded March 2025 · Episode 4 · 10:34 In this episode I examine the incorporation of a property rental business held by a partnership or LLP into a limited company. I explain the potential advantages, including the availability of incorporation relief […]
Read MoreTax Aspects of UK Corporate Demergers
Tax Aspects of UK Corporate Demergers Recorded May 2025 · Episode 11 · 14:57 In this episode I work through the tax treatment of corporate demergers, the process by which a company or group is split into separate parts. I explain the three principal routes — the statutory (exempt) demerger, […]
Read MoreStatutory Residence Test – Common Errors
Statutory Residence Test – Common Errors Recorded May 2025 · Episode 10 · 5:09 In this episode I look at the mistakes most often made in applying the statutory residence test. I explain the correct order in which to work through the automatic overseas tests, the automatic UK tests and […]
Read MoreSDLT Mixed Use and Recent Cases
SDLT Mixed Use and Recent Cases Recorded May 2025 · Episode 9 · 5:01 In this episode I examine when a property purchase can be treated as mixed use for stamp duty land tax, so that the lower non-residential rates apply rather than the residential rates and the surcharge. I […]
Read MoreEMI Options – An Update
EMI Options – An Update Recorded May 2025 · Episode 8 · 6:49 In this episode I explain enterprise management incentive options, one of the most tax-efficient ways for a smaller company to attract and retain key people. I set out the qualifying conditions for both the company and the […]
Read MoreUK Corporate Tax Residence and HMRC’s Approach
UK Corporate Tax Residence and HMRC’s Approach Recorded March 2025 · Episode 7 · 10:02 In this episode I examine when a company is resident in the United Kingdom for tax purposes and how HMRC approaches the question. I explain the central management and control test that sits alongside the […]
Read MoreTax Risks of Liquidation Distributions – Navigating the TAAR
Tax Risks of Liquidation Distributions – Navigating the TAAR Recorded March 2025 · Episode 6 · 7:34 In this episode I examine the risk that a distribution made in the course of winding up a company is taxed as income rather than capital, under the targeted anti-avoidance rule. Where the […]
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