Category: Podcast
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 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 […]
Read MoreEmployee Ownership Trusts after the 2024 Budget
Employee Ownership Trusts after the 2024 Budget Recorded March 2025 · Episode 1 · 9:48 In this episode I examine employee ownership trusts and, in particular, the changes introduced in the October 2024 Budget. An EOT allows a controlling interest in a company to be sold to a trust for […]
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