Corporate Groups and the Degrouping Rules – Comparing Capital Gains and IP Groups

 Corporate Groups, Corporate Tax, IP Tax  Comments Off on Corporate Groups and the Degrouping Rules – Comparing Capital Gains and IP Groups
Apr 222013
 

We have seen in previous articles how the degrouping rules operate to prevent the use of a corporate vehicle to shelter taxable gains. There are two sets of rules, one for capital assets and the other for intangibles (“IP”). In this article we shall look at how these rules differ, giving a specific example involving a business sale.

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

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Corporate Tax Groups – Degrouping IP

 Corporate Groups, Corporate Tax, IP Tax  Comments Off on Corporate Tax Groups – Degrouping IP
Apr 212013
 

In this article, we shall discuss the degrouping rules as they apply to intangible assets such as IP and goodwill (collectively referred to as IP). The tax treatment is similar to that applying to capital assets, but with important differences.

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

Buying Corporate Tax Losses – Part Two

 Corporate Tax  Comments Off on Buying Corporate Tax Losses – Part Two
Apr 102013
 

In Part One, we saw how a company with tax losses can be prevented from claiming tax relief following a takeover. In particular, the carry forward of past trading losses is disallowed if there have been “major changes in the nature and conduct” of the company’s trade.

In this article, we shall take a closer look on what this phrase actually means. Continue reading »

Budget 2013 – New Limits on Income Tax Reliefs

 Budget 2013, Income Tax  Comments Off on Budget 2013 – New Limits on Income Tax Reliefs
Apr 102013
 

Budget 2013 has produced a few nasty restrictions on income tax reliefs, which cannot be said to be business friendly at all. In a nutshell, certain types of tax deduction will be capped at 25% of an individual’s annual income, or £50,000, whichever is the greater number.

The Draft Guidance sets out a list of the reliefs affected, and examples of how to do the sums. Perhaps the most significant impact will be felt by individuals setting up their own business, whether as a sole trader or in partnership. Continue reading »

Buying Corporate Tax Losses – Part One

 Corporate Tax  Comments Off on Buying Corporate Tax Losses – Part One
Apr 082013
 

It is well known that during a recession, many businesses are forced to close down due to financial difficulties. While this is bad news for the owners, it can provide attractive buying opportunities, especially if there are trading losses available for which a purchaser is prepared to pay an acceptable price. Continue reading »