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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. But how should those loan notes […]
Read MoreTransferring 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 under s.162 TCGA 1992 to defer the capital gains […]
Read MoreTax 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, the capital reduction demerger and the […]
Read MoreStatutory 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 the sufficient ties test, why that […]
Read MoreSDLT 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 look at the recent run of […]
Read MoreUK 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 incorporation rule, what the case law tells […]
Read MoreTax 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 conditions are met — broadly, where the individual carries […]
Read MoreTax Implications of Divorce Settlements
Recorded March 2025 · Episode 3 · 4:33 In this episode I consider the tax consequences of divorce and separation. I look at the capital gains tax treatment of transfers of assets between separating spouses and civil partners, including the no gain, no loss window and the more generous rules […]
Read MoreInheritance Tax Changes after the 2024 Budget
Inheritance Tax Changes after the 2024 Budget Recorded March 2025 · Episode 2 · 6:30 Update note (June 2026): Two things have moved since this episode was recorded. The residence-based system that replaced domicile is now in force, having taken effect on 6 April 2025. More significantly, the agricultural and […]
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