Tag: CGT
Business Asset Disposal Relief – 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 trip up the unwary. The […]
Read MoreTo 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 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 MoreCarried Interest – when it arises and how much is the UK gain?
Carried interest – when it arises and how much is the UK gain? Our previous blog article on the new rules for the taxation of carried interest looked at their general impact on investment managers, including the introduction of the concept of income-based carried interest (“IBCI”) and the rule that […]
Read MoreCarried interest, co-invest and tax planning
Carried interest, co-invest and tax planning The new rules affecting the compensation of investment managers have now come into full effect. The changes Broadly, these are as follows: Carried interest now falls into one of two categories; Income Based Carried Interest (“IBCI”) which is subject to income tax and NIC, […]
Read MoreSome tax avoidance schemes do work
Some tax avoidance schemes do work… “Some tax avoidance schemes do work. They avoid tax by adopting a legitimate, justifiable and commercially sensible structure to achieve a result which could be achieved by other legitimate and justifiable means. Where, however, that structure is artificial or has no purpose other than […]
Read More