Finance Bill 2016 – Corporate Tax, IP and Partnerships

 Corporate Tax, IP Tax  Comments Off on Finance Bill 2016 – Corporate Tax, IP and Partnerships
Jan 272016
 

In the last two Budgets, the Government did a lot of heavy tinkering with the rules on goodwill related intangibles. In the first Budget of 2015, they stopped tax relief when a company acquired such assets from a related party, and in the second, Summer Budget of 2015, they extended this treatment to unrelated parties. One would have expected the Big Bad Wolf to be satiated by now, but it seems not – Autumn Statement 2015 has given us yet another set of restrictions on intangibles related tax relief.

Continue reading »

Summer Budget 2015 – Goodwill Regained – but for how long?

 Corporate Tax, IP Tax  Comments Off on Summer Budget 2015 – Goodwill Regained – but for how long?
Aug 142015
 

In a previous article we saw how the Government spoilt everyone’s fun by abolishing corporate tax relief on goodwill when acquiring a business. But there may be a silver lining to our goodwill cloud, though how long this will last remains to be seen.

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

Continue reading »

Rollover Reliefs and the Replacement of Business Assets Part Three – Rolling IP into Shares

 Corporate Groups, Corporate Tax, IP Tax  Comments Off on Rollover Reliefs and the Replacement of Business Assets Part Three – Rolling IP into Shares
Feb 222015
 

This is the last article in our series on asset rollovers. In Part One, we looked at capital assets, in Part Two we saw how IP rollovers work. In this part we shall see how it is possible to sell an IP asset and defer the tax by reinvesting the proceeds in the shares of a company, effectively looking through the corporate vehicle to the underlying IP that it holds.

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

Continue reading »

Rollover Reliefs and the Replacement of Business Assets Part Two – IP Rollovers

 CGT, Corporate Tax, IP Tax  Comments Off on Rollover Reliefs and the Replacement of Business Assets Part Two – IP Rollovers
Feb 202015
 

This is the second article in our series on asset rollovers. In Part One, we looked at capital assets, in this part, we shall look at IP (we shall use the term IP to cover all intangibles including goodwill).

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

Recall that a rollover is a means of deferring tax when a business asset is sold and replaced with another. The idea is that since the sale proceeds have been reinvested, the tax doesn’t become due until the second asset is sold and the funds become available.

Continue reading »