Budget 2013 – Buying Corporate Tax Losses – a technical analysis of the new rules on trading losses

 Budget 2013, Corporate Tax, Tax Avoidance  Comments Off on Budget 2013 – Buying Corporate Tax Losses – a technical analysis of the new rules on trading losses
Mar 262013
 

This is a technical analysis of the new restriction on the carry forward of trading losses when a company undergoes a change in ownership. The legislation refers to the Corporation Tax Act 2010 (“CTA 2010”).

Tax specialists will be familiar with the subject matter. For those who are not so familiar with these rules, there is another article to follow. Continue reading »

Mar 222013
 

There are a number of anti-avoidance measures aimed at closing various loopholes in the corporate tax legislation. These are all targeted at loss buying – on top of the loophole closures, we have two new targeted anti-avoidance rules, or TAARs as we like to call them in the tax world. Continue reading »

Mar 222013
 

The actual measure is aimed at certain “non-natural persons” and is stated to be a CGT measure. While CGT is one of the taxes involved in this anti-avoidance package, it is in substance a  penalty against wealthy individuals seeking to save stamp duty land tax (“SDLT”) when buying a home through an offshore company.  Continue reading »

Budget 2013: Investments – Seed Enterprise Investment Scheme and Stamp Duty Reserve Tax

 Budget 2013, Investment Tax  Comments Off on Budget 2013: Investments – Seed Enterprise Investment Scheme and Stamp Duty Reserve Tax
Mar 222013
 

Some good news for investors in this year’s Budget. And do they need it in the current economic climate. Continue reading »

Corporate Tax Groups – the Capital Gains Degrouping Rules – Part Two

 Corporate Groups, Corporate Tax  Comments Off on Corporate Tax Groups – the Capital Gains Degrouping Rules – Part Two
Mar 192013
 

In Part One, we saw how the degrouping rules prevent capital assets from leaving a group tax free within a corporate wrapper. This article finishes off with a few miscellaneous, but important points concerning the operation of these rules.

(This article is Part Two of a two part mini-series on the Capital Gains Degrouping Rules. Both parts can be read in a single article in pdf format which can be downloaded at Academia.edu.)

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Corporate Tax Groups – the Capital Gains Degrouping Rules – Part One

 Corporate Groups, Corporate Tax  Comments Off on Corporate Tax Groups – the Capital Gains Degrouping Rules – Part One
Mar 172013
 

This is the third article in our series on corporate tax groups where we explore the rules governing intra-group transactions, and how they are taxed. In this article we shall look at the rules relating to capital assets.

(This article is Part One of a two part mini-series on the Capital Gains Degrouping Rules. Both parts can be read in a single article in pdf format which can be downloaded at Academia.edu.)

Continue reading »

Property Tax – How options can be used to defer tax on a property sale

 CGT, Property Tax  Comments Off on Property Tax – How options can be used to defer tax on a property sale
Mar 162013
 

As we approach the end of the tax year – and hopefully the start of spring – a lot of people will go into frantic mode as they discover that they may need to do some last minute tax planning.

It happens every year. In the next few weeks, expect your local friendly bank and other financial institutions to send you an invitation to invest in their ISA product, and even closer to the deadline, expect to see adverts telling you that you can even apply online. The things that our respected banks and building society do to get an honest crumb!

But one sort of tax planning actually depends on delaying, rather than acting early.

(This article can be downloaded in pdf format at Academia.edu.)

Continue reading »

Corporate Tax Groups – Intra-group Transfers are Tax Neutral

 Corporate Groups, Corporate Tax  Comments Off on Corporate Tax Groups – Intra-group Transfers are Tax Neutral
Mar 112013
 

This is the second in a series of articles in which we explore the tax rules applying to intra-group transactions. In the first article we looked at the basic definition of a corporate group as it applies to the capital gains tax and IP legislation. We shall now see how the legislation ensures that intra-group transactions are tax neutral.

(This article can be downloaded in pdf format at Academia.edu.) Continue reading »